Comment Log Display

Dear Chair Randolph and Executive Officer Cliff,

Our full comments are attached; the following is a summary of key
points.  We appreciate the opportunity to comment on the Low Carbon
Fuel Standard LCFS rulemaking.

Pearson Fuels is the largest distributor of E85 in California,
supplying more than 325 public and private fueling locations across
the state. 

Pearson Fuels is an ardent supporter of the LCFS.  As recognized in
the 2022 Final Scoping Plan ("Scoping Plan"), the LCFS program is
the most effective program in the transportation sector.  The
Scoping Plan similarly recognizes that increasing the rate of LCFS
carbon intensity ("CI") reductions and extending the schedule of CI
reductions is essential to California's success in fulfilling the
requirements of AB 32 and achieving carbon neutrality by 2045.  

In order to fully leverage the tremendous market power of the LCFS
to decarbonize the transportation sector, we recommend that the
Governing Board direct CARB staff to fully explore the following
specific issues to inform the development of proposed amendments to
the LCFS:
•	Low carbon fuels such as E85 are often priced below conventional
fossil fuels and these fuels save consumers' money, reduce
greenhouse gas ("GHG") emissions, reduce criteria pollutant
emissions, and diversify the transportation fuels market.
•	California marketers have identified and promoted E85 as a
consumer-friendly fuel; built out a massive E85 station network
particularly in disadvantaged communities; and leveraged
California's existing FFV fleet to reduce petroleum dependence and
GHG emissions.
•	California should continue to utilize biofuels as a vitally
important GHG reduction strategy; further leverage its existing FFV
fleet to reduce GHGs in the light-duty sector; and utilize biofuels
including E85 to achieve carbon neutrality to supply internal
combustion engines that will remain on the road beyond 2045.
•	Through the use of the full range of low carbon fuels available
to California, it is feasible for California to achieve a CI
reduction goal of 35% by 2030, as we've advocated for previously.
ICF International shows the potential for a target reduction of 42%
for 2030 through modeling it has done for the Low Carbon Fuels
Coalition and other stakeholders.

In addition to these LCFS program recommendations, we recommend
that CARB explore ways to establish other types of policy support
for flex fuel vehicles ("FFVs") to complement the support that is
provided to zero emission vehicles ("ZEVs").  

Best Regards,
Graham Noyes, Noyes Law Corporation
for Pearson Fuels