Comment Log Display

June 17, 2015


The Honorable Mary Nichols, Chairwoman
California Air Resources Board
1001 I Street
Sacramento, CA 95814

Subject:	Comments on Low Carbon Fuel Standard’s (LCFS) provisions
for Low Complexity – Low Energy (LCLE) Refiners
	
Thank you for allowing us to provide our comments on the Low Carbon
Fuel Standard’s (LCFS) provisions for Low Complexity – Low Energy
(LCLE) Refiners. These provisions recognize that not all refineries
are the same.  We believe that there are policy and technical
justifications for a distinction in the LCFS.  The Air Resources
Board, as well as, the U.S. Environmental Protection Agency has
traditionally recognized the unique value small refiners occupy in
the oil and finished fuel markets, as well as, their unique
configurations and operating constraints.

Given the value of LCLE Refiners, we were concerned that the
proposed final regulatory proposal for the re-adoption of
California’s LCFS fails to recognize Alon’s Bakersfield Refinery as
a LCLE producer. The facility is configured and engineered to
produce low carbon intensive base fuels. Board staff had an
opportunity to make the LCFS’s LCLE provisions work for all low
carbon intensity refineries in California, but decided against
various compromise proposals presented, including proposals to
limit the benefit any single LCLE refiner could receive.

As the final LCFS regulation is before you, we ask that the Board
please look again at the value of all LCLE refineries and the
benefits that they provide to the state.  Thank you again for
allowing us to provide our comments on the re-adoption of the
LCFS.

Sincerely,




ANDY VIDAK
Senator, 14th District	



JEAN FULLER,
Senator, 16th District