Comment Log Display

February 5, 2024

California Air Resources Board
1001 Street
Sacramento, CA, 95814

SUBJECT: California Air Resources Board (CARB): Low Carbon Fuel
Standards: Elimination of Intrastate Fossil Jet Fuel Exemption -
OPPOSE

Dear Members of the California Air Resources Board,

The Valley Industry & Commerce Association (VICA) asserts its
opposition to the proposed elimination of the Low Carbon Fuel
Standard (LCFS) exemption for intrastate fossil jet fuel. We firmly
believe that the current proposal, if implemented, would fall short
of achieving its intended goal to increase Sustainable Aviation
Fuel (SAF) production and mitigating greenhouse gas emissions,
while inevitably leading to significant economic burdens on the
aviation industry, travelers, and consumers.

VICA recognizes the aviation industry's commitment to voluntarily
using cleaner alternatives in aviation fuel, as exemplified by the
production of over 11.6 million gallons of Alternative Jet Fuel in
2022, working in alignment with California's environmental
objectives to reduce greenhouse gas emissions. However, VICA
contends that the proposed CARB regulation faces critical
challenges to its feasibility that would, ultimately, undermine its
core objective of enhancing SAF and Alternative Jet Fuel (AJF)
utilization.

A core issue is the limits on AJF or SAF production. While SAF is
being developed and provided, the technological landscape currently
would not align with CARB's stringent requirements, as there is
currently a shortage of producers capable of meeting the demand for
AJF and SAF. Technological limitations would also impede the
industry's ability to scale up AJF and SAF production to meet
proposed standards; therefore, imposing such regulations would be
premature, undoubtedly harming the industry and leading to adverse
consequences for the broader economy.

The anticipated escalation of costs for the aviation industry
resulting from this CARB ruling would not only impact aviation
providers, but also directly affect travelers in the form of
substantial airfare and fee hikes. These economic burdens would
impede the movement of travelers while increasing the cost for the
shipment of goods and products, resulting in increased costs for
individuals, families, and businesses.


Considering these substantial concerns, VICA strongly urges CARB to
reconsider the proposed LCFS exemption elimination and instead
focus on a collaborative approach with the aviation community that
allows for necessary technological advancements and infrastructure
development before stringent regulations are considered. This
approach would ensure a seamless transition to cleaner aviation
fuels without compromising our economic stability.

For these reasons, we staunchly oppose the proposed ruling.

Sincerely,

Stuart Waldman
VICA President