Comment Log Display

On behalf of River City Petroleum, we represent our concerns
regarding the Low Carbon Fuel Standards set to be implemented in
January for the upcoming year. After reading, analyzing and
speaking with peers in the industry, it is apparent numerous
unanswered questions remain regarding the regulation.  Will the
costs of the implementation truly outweigh its benefits? It is
apparent that it will cost a significant amount of money to achieve
the stated goals as the standard is currently laid out. What is
troublesome is that a definitive answer as to what is to be
accomplished has yet to be answered.  Whatever it is, the costs
will ultimately be passed on to consumers.  How much of an increase
will they pay at the pump? Is it realistic to expect consumers to
pay these increases with the current economy in such an unstable
state? Accompanying our concern for costs; how it is expected the
supply of “low carbon” fuel to be sustainable, especially if other
states are expected to implement similar programs. The LCFS bill
makes clear the methods for finding the Carbon Intensity are
imperfect and “subject to change” based on new findings.  This
instills very little confidence in the program, when there are many
questions left unanswered.  River City Petroleum therefore requests
the implementation of the Low Carbon Fuel Standard be postponed
until all costs and benefits of the program are weighed out and a
more accurate measurement of them are able to be derived.