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I wish to provide comment on the recent proposal by CARB to phase
out the LCFS credit eligibility of electric forklifts post-2025.

Our company, Greenscape Financial, is in the business of
aggregating, monetizing, and financing the credits generated by
electric industrial equipment, including electric forklifts. Our
business provides owner/operators of electric equipment upfront
lump-sum cash payments in exchange for the right to register the
credits generated from electric charging of this equipment over a
multi-year period. The customers can use those upfront proceeds for
any corporate purpose, including purchasing more electric
equipment. Our upfront payments are effectively a financial rebate
on the purchase or lease of new electric cargo handling equipment,
which eases the customer's transition away from higher carbon
propane lifts towards the typically more expensive zero-emission
vehicles.

We formed our company in 2021 based on CARB's publicly stated
commitment to the LCFS regulation. On that basis, my partner and I
have made significant investments for the long-term which we
believe we benefit our customers, service providers, and local
communities. Unfortunately, that whole model has now been thrown
into disarray as as result of CARB's recent pronouncements. As we
stand today, we are not able to offer customers contracts beyond
three years given the complete lack of visibility in regards to the
potential for credit generation. Our customers are similarly
hesitant to sign up for contracts to participate in a program that
now appears to lack long-term support from California regulators. 


Recent data shows that only 50-55% of California's forklift fleet
is electric, leaving a huge swath of the market (~50,000 forklifts)
that still run on propane and must be converted. So why pull the
rug out now, particularly when this program has proven so effective
to date? The decision seems rather arbitrary and more aimed at
addressing low LCFS credit prices than the efficacy of a program
that continues to yield results. If CARB is concerned about excess
credit generation swamping the LCFS market, a much more logical
solution would be to raise the stringency requirements on carbon
intensity levels as it has done historically. 

We would also suggest that all FSEs be required to install meters
that produce empirical data, rather than the "guesstimation" method
allowed by CARB and currently used by most vendors of electrical
forklift credits. Market observers estimate that this method of
credit calculation probably overstates credit generation by as much
as 20-30% annually. Mandating metering of electric forklift credits
would therefore significantly reduce the pool of credits generated
from this category while preserving the integrity of the program. 

We strongly encourage CARB not to interfere with a program that has
been a model of public/private partnership and has produced results
that are additive to the objectives of the LCFS. At the very least,
CARB needs to provide a longer-term transition period (e.g. ~10
years) for a change of this magnitude, with plenty of runway and
visibility for market participants. Otherwise we fear the
disruption and uncertainty created by such a precipitous move will
be felt well beyond the forklift space, and will ultimately prove
counterproductive to CARB's oft-stated objective of attracting and
retaining private investment to facilitate California's transition
to green energy.

Thank you for your attention to this matter.

Jame Donath
Chairman
Greenscape Financial Group, Inc.