Comment Log Display

Dear Chair Randolph and Executive Officer Cliff,

We are writing to request that the California Air Resources Board
(CARB) work together with other California agencies and the federal
government in the current Low Carbon Fuel Standard (LCFS)
rulemaking to update CARB's life cycle analysis modeling (LCA) to
reflect the reductions in greenhouse gas (GHG) that result from the
conversion of the woody biomass cleared during forest treatment
into low carbon fuels.  On a parallel track, we request that CARB
update its air quality and health effects models to recognize the
severe impacts of recurring and extended wildfires on fire-exposed
communities.  These updates are critical given the recent massive
expansion of GHG and criteria pollutants generated annually by
climate change induced California wildfires.  

As an exhibit to this letter, we have attached a White Paper for
Policy Makers entitled "Turning Wildfire Tinder Into Low Carbon
Fuels."   This White Paper documents the rapid expansion of
California wildfires, provides a comprehensive set of state and
federal policy recommendations, and provides technology overviews
from the leading companies in the sector.

The complete comment is attached.  Please contact me for any
questions or follow up.  Thank you for your consideration of this
input.

Best Regards,

Graham Noyes
Noyes Law Corporation
fuelandcarbonlaw.com