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Comment 19 for Public Meeting to Hear an Update on the Low Carbon Fuel Standard (lcfsupdate2023) - Non-Reg.

First NameEvan
Last NameEdgar
Email Addressevan@edgarinc.org
Affiliation
SubjectZEV Batteries as a transportation fuel has a average CI of 76
Comment
We have worked closely with EJAC on the development of the 2022
Scoping Plan Update and the proposed California ZEV Battery
Directive, which included the need to prepare a Life Cycle Analysis
(LCA) for ZEVs. As part of the Scoping Plan process, the need to
conduct LCAs for ZEV batteries was cornerstone in our comments sent
to CARB and EJAC. As part of the upcoming LCFS regulations, ZEVs
batteries usage as a transportation fuel need to be included in the
LCFS regulations with a life-cycle assessment, where the average
carbon intensity based upon recent European Studies is 76 g CO2/MJ.

Attachment https://ww2.arb.ca.gov/sites/default/files/BARCU/barcu-attach/21-lcfsupdate2023-VzRWMV0uUmMFXARo.pdf
Original File NameCARB LCFS meeting Submittal Sept 28 2023.pdf
Date and Time Comment Was Submitted 2023-09-28 11:03:40