Comment Log Display

December 15, 2011

Mary D. Nichols, Chair
Members of the Governing Board
California Air Resources Board
1001 “I” Street
P.O. Box 2815
Sacramento, CA 95812

RE: 	Clean Energy strongly supports the proposed Amendments to the
Low Carbon Fuel Standard Regulation as presented by staff.


Dear Chairman Nichols and Members of the Air Resources Board,


Clean Energy is in strong support of the proposed amendments to the
Low Carbon Fuel Standard (LCFS) Regulation before the Governing
Board.  It is our belief that staff has carefully reviewed the
program’s progress through this initial year and has determined
that not only is the program solvent for compliance purposes, but
that low carbon fuel production is continuing to ramp up to meet
the needs of regulated parties to achieve the standard’s 2020 low
carbon fuel reduction goal of 10 percent.

Clean Energy staff has worked very closely with Air Resources Board
(ARB) staff over the past few years to address a number of the
Natural Gas Vehicle Industry’s concerns pertaining to the initial
rulemaking.  These concerns dealt with the original Energy
Efficiency Ratio applied to medium- and heavy-duty natural gas
vehicles, fuel quality concerns for mobile applications for
territories covered by Southern California Gas Company and San
Diego Gas & Electric utilities, and the ability for renewable
natural gas fuel providers to deliver this ultra low carbon product
to the California market in an efficient and enforceable manner. 
Further, Clean Energy was an active participant of the LCFS
Advisory Committee and would like to commend the leadership of Mr.
Richard Corey and his staff for professionally addressing many
stakeholders concerns by providing reasonable and well thought out
solutions that make the LCFS regulation functional.

Clean Energy was proud to make up nearly nine percent of the LCFS
credit market for the first quarter of 2011.  As we start to deploy
our American Natural Gas Highway in 2012 and ramp up our production
of renewable natural gas (also known as biomethane) through our
subsidiary, Clean Energy Renewable Fuels, we hope to demonstrate to
this agency that natural gas, conventional and renewable, can and
will provide a meaningful low carbon fuel solution to the
transportation sector for decades to come.  Thank you.

Sincerely,



Todd R. Campbell