Comment Log Display

After a review of the changes proposed by the ARB for the LCFS
program, we would like to express our support for the modifications
and considerations made by ARB staff.

There are two specific items that LCE and DE would like to include
in upcoming amendments to the LCFS regulations, each relates to how
CCAs can participate in the LCFS market.  First, the ARB should
clarify that CCAs are eligible entities that can register for
non-residential EV LCFS credits through the proposed Section
95483.2(b)(8).  Second, the ARB should reconsider the allocation of
Residential EV Charging credits to not just electric distribution
utilities (EDUs), but also to CCAs.  This change will allow the
growing CCA customer base access to LCFS revenues to support EV
incentive programs.