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Dear ARB Staff,

Thanks for the opportunity to comment on the proposed amendments to
the LCFS. We would like to focus on the verification approach
only.

- The amendment does not consider the existence of already well
established certification schemes. The use of multi stakeholder
certification schemes can be considered as best practice. Such
schemes work efficient, have technical competencies, work globally,
are not restricted by public sector constraints, and can re-act
quickly to market changes
- The approach chosen by ARB will lead to tremendous additional
costs for companies as verification / certification for different
markets will require multiple audits. 
- The approach chosen will increase complexity and risk of fraud,
as independent verifications will take place without the option to
assess supply and delivery in international supply chains and to
different regulatory systems. This could result in double-claiming
of certain feedstock characteristics and CI numbers
- It is extremely important to control global supply chains,
particular for low carbon feedstock. It is unclear how this will be
implemented.
- Government authorities can efficiently control certification
schemes. Using certification schemes would not mean that Government
authorities give away responsibilities of public authorities.

Kind regards,
Norbert Schmitz 
Jan Henke
ISCC System GmbH
Hohenzollernring 72
D-50672 Cologne