Comment Log Display

Ravi Sekhon
rsekhon@centerlinelogistics.com
(206) 550-7659

August 27, 2024

California Air Resources Board (CARB)
1001 I Street
Sacramento, CA 95814

Subject: Support for Including Green Methanol as a Marine Fuel in
the LCFS

Dear California Air Resources Board Members,

I am submitting this letter in support of including green methanol
as a marine fuel in the Low Carbon Fuel Standard (LCFS). I believe
that CARB should actively promote the increased production, sale,
and utilization of green methanol not only to lower carbon
emissions but also to enhance air quality in our communities.

Green methanol offers significant environmental benefits when
compared to conventional marine fuels like diesel. It can reduce
carbon dioxide emissions by as much as 95%, cut nitrogen oxide
emissions by up to 80%, and completely eliminate emissions of
sulfur oxides and particulate matter. These substantial reductions
make green methanol a cleaner and more sustainable option for
marine transportation.

One of the major advantages of green methanol is that the existing
infrastructure in California can handle this fuel. Storage tanks
currently used for traditional marine fuels can be repurposed to
store green methanol, and barges used to transport conventional
bunker fuels within the ports can similarly be adapted for green
methanol. This flexibility reduces the time and cost associated
with transitioning to green methanol, as it avoids the need for
completely new infrastructure. In contrast, other zero-carbon or
low-carbon marine fuels that are being considered would require the
construction of entirely new facilities and equipment, which would
take years to permit and build. 

Amending the LCFS regulations to permit low-carbon-intensity (CI)
green methanol to generate credits when used in specific
applications, such as marine transportation, would create
incentives for its adoption. This change would encourage its use in
place of traditional fossil fuels, ultimately helping to decrease
overall emissions in these sectors.

Such a change aligns perfectly with CARB's dual objectives of
improving local air quality and tackling the global challenge of
climate change. The growing demand for green methanol in various
transportation sectors, particularly in the maritime industry,
underscores its potential. Many major transportation companies are
transitioning their fleets to run on green methanol, with numerous
vessels expected to call on California's ports. Therefore,
fostering the production and use of green methanol within the state
is of critical importance.

This initiative also complements efforts by California's port
authorities to address emissions from the marine transportation
sector. For example, the San Pedro Bay Ports Clean Air Action Plan
(CAAP), adopted in 2006, outlines a comprehensive strategy to
reduce pollution from ocean-going vessels and other port-related
sources.

As CARB acknowledged in the 2022 Climate Scoping Plan, marine
transportation is a challenging sector to decarbonize. Continued
support for low-carbon liquid fuels is essential as the industry
transitions away from fossil fuels. One effective way to maintain
this support would be to amend the LCFS regulations to include
green methanol as an optional fuel for marine transportation. Many
stakeholders have expressed this need in their comments on the
ongoing rulemaking package, and I urge CARB to act swiftly to
incorporate this change.

Thank you for considering this matter. I appreciate your leadership
in addressing both local air quality and global climate issues and
your efforts to support innovative low-carbon solutions.


Sincerely,

Ravi Sekhon