Comment Log Display

The attached PDF contains comments submitted by the International
Council on Clean Transportation (ICCT). The ICCT is an independent
nonprofit organization founded to provide unbiased research and
technical analysis to environmental regulators. Our mission is to
improve the environmental performance and energy efficiency of
road, marine, and air transportation, in order to benefit public
health and mitigate climate change. We promote best practices and
comprehensive solutions to increase vehicle efficiency, increase
the sustainability of alternative fuels, reduce pollution from the
in-use fleet, and curtail emissions of local air pollutants and
greenhouse gases (GHG) from international goods movement.

The ICCT welcomes the opportunity to provide comments on the Air
Resources Board's Proposed Low Carbon Fuel Standard amendments. We
commend the agency for its technical analysis and interest in
continuing to improve the effectiveness of one of its flagship
climate programs. Based on the content of the Initial Statement of
Reasoning (ISOR) document, the comments below offer a number of
technical observations and recommendations for ARB to consider in
aligning the program with the goals of the 2022 Scoping Plan.