Comment Log Display

Please find the attached comment submit jointly by Infinium,
Twelve, Air Company, Arcadia eFuels, Dimensional Energy, Boom and
the International Airlines Group. A brief summary of the comment is
included below.  Please contact me regarding any issues or
questions relating to the comment.  

Thank you for your assistance.

Best Regards,
Graham Noyes
Noyes Law Corporation

Comment Summary:
The signatories of this letter are pleased to submit comments
recommending a modification to the California Air Resources Board's
("CARB") proposed amendments to the Low Carbon Fuel Standard
("LCFS"). We support CARB's LCFS program, as it sends a market
signal to decarbonize the transportation sector, is performance
based, and provides long-term policy stability that supports
investment. However, we respectfully request that CARB maintain
LCFS policy stability for the clean fuels industry and preserve the
eligibility of facilities that produce Power-to-Liquid ("PtL")
fuels to source low-carbon intensity electricity ("Low-CI
Electricity") via book-and-claim accounting. PtL fuels, also known
as eFuels, electrofuels or synthetic fuels, are drop-in replacement
fuels for use in airplanes, ships and motor vehicles that do not
trigger the costs or delays inherent to engine or infrastructure
changes. Specifically, we
request that CARB preserve the current renewable energy certificate
("REC") system for electrolytic hydrogen and enable the sourcing of
energy for PtL fuel production via book-and claim accounting.