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Ladies and Gentlemen,
  I'd like to congratulate you on the admirable document, LCFS09. 
I sincerely hope it is adopted.  I would like to suggest that you
also consider another method to reduce carbon emissions as well as
the usual suspects (NOx, etc).
  No doubt you have considered it, but why not just move ahead
with a regulation to "end idle" in passenger cars as well as diesel
trucks, buses, etc.  By this, I mean that no cars should have their
internal combustion engines running at speeds of, let's guess,
roughly 2 mph or less, whether braking or accelerating.
  All of the Big-3 have vehicles that have at least mild-hybrid
technologies (batteries & electric motors supporting internal
combustion engines), and some have more sophisticated units,
similar to the Prius.  Mild hybrids alone save ~ 15% of gas
consumption, and therefore the commensurate amount of CO2
emmisions.  Furthermore, this would have very beneficial
consequences with respect to particulates and perhaps other
pollutants, since it is during the initial acceleration of the
vehicle when many of these products are most significant.  The best
thing about the goal of merely ending idle is that no technology
development need occur.  It's already here, but the deployment is
sparse.
  In terms of implementation, of course, one may not want to
regulate this based solely on speed alone.  Certainly there need to
be exceptions, such as when the car is in the shop for maintenance.
 But, particularly for trucks, a speed-based standard may be not be
correct when, say, the truck is stopped on an uphill incline - in
that case, additional torque may be needed from the IC engine to
get the truck running.  Perhaps the standard could be that the IC
engine should not be running for speeds less than, say, 2 mph, on a
level road, or at a comparable torque level for inclines.   Also,
units with, say, natural gas engines or similar could be exempted,
if desired.
  This could even be applied to trains - GE has such a train now.

Keep up the good work!