Comment Log Display

September 19, 2022

California Air Resources Board
1001 I Street
Sacramento, CA 95814

SUBJECT: Public Workshop to Discuss Potential Changes to Low Carbon
Fuel Standard

To Whom it May Concern,

On behalf of CALSTART, I want to extend our appreciation for the
opportunity to submit feedback regarding the potential changes to
the Low Carbon Fuel Standard (LCFS) program. Since its initial
implementation 2011, the LCFS program has allowed California to
decrease carbon in our state's fuel pool and accelerated new
technology and alternatives to petroleum fuel. The program has also
served a valuable incentive program in helping bring new companies
and their ideas for zero-emission fuels and technology into the
state's fuel market.     

CALSTART and our Origins
CALSTART is a California-based, international nonprofit that is a
recognized clean transportation technology consortium. Our 300+
members are all dedicated to the growth of the clean transportation
industry, and we work with public and private sectors to drive
innovation in the sustainable transportation sector. CALSTART
membership is comprised of vehicle manufacturers, transit agencies,
public and private fleets, mobility partners, parts and component
manufacturers, EV charging station and hydrogen refueling
providers, battery manufacturers, and more. 

Founded in Southern California in 1972, CALSTART has provided
services and consulting to spur advanced transportation
technologies, fuels, systems, and the companies that make them.
Since our inception, CALSTART has partnered with California and
several states to enact groundbreaking policies aimed at reducing
and eliminating emissions from the transportation sector. We also
administer several programs in California and across the country
that help provide funding to fleets, companies, and manufacturers
to help accelerate zero-emission vehicle adoption. 

CALSTART's latest initiative, The Global Drive to Zero, has our
staff working with foreign governments, sub-national governments,
and industries to achieve a 100 percent zero-emission new truck and
bus sales goal by 2040 with an interim 2030 mark of 30 percent
zero-emission vehicles sales. 

LCFS Past, Present, and Future
California's LCFS program is a model for other states in their
efforts to curb the carbon intensity (CI) of transportation fuels.
Currently, California's LCFS program is projected to decrease CI
below the 20 percent goal by 2030. 

CALSTART recommends CARB extend the LCFS program to 2045, with
interim CI targets set up every five years (2035, 2040). This
timeline matches up with the Governor's Executive Order (EO
N-79-20) to turn over 100 percent of the truck fleets to
zero-emission by 2045. That date also would incorporate programs
like Advanced Clean Cars II, Advanced Clean Trucks, and Advanced
Clean Fleets. 

For the near future, California should aim for the highest CI
reduction target possible for 2030. Out of the options provided,
CALSTART asks CARB to make Option B (30 percent CI reduction by
2030 compared to 2010) the goal. 

In July, Governor Newsom wrote a letter to CARB Chair Randolph 
pushing for "greater opportunities to reduce our dependence on
fossil fuels to achieve our air quality and climate targets," and
continue the diversification of fuels away from petroleum in the
transportation sector. Part of his ask was to evaluate and consider
an increase in the stringency of the LCFS. With that said, CALSTART
asks CARB to evaluate whether the 2030 goal can be even more
aggressive than Option B and use 30 percent as the floor on what a
strong and realistic CI reduction goal should be. CALSTART also
encourages CARB staff to look at Oregon and their current proposals
for CI reduction. A possible 2035 goal could be to align California
and Oregon with 37 percent CI reduction.   

Moving forward, CALSTART believes the setting of more stringent
goals in 2030 and out years will send a strong signal to the
marketplace and investors. A commitment to an increasingly more
ambitious CI reduction would lead to more money entering the
industry and helping California increase the clean fuel options
available to customers. 

Infrastructure Crediting into the Future: 
CALSTART encourages CARB to expand capacity credits for Fast
Charging Infrastructure (FCI) and Hydrogen Refueling Infrastructure
(HRI). The medium- and heavy-duty (MHD) transportation sector
disproportionately accounts for harmful emissions comparative to
the number of vehicles they have on the road. CARB expanding credit
pathways to support MHD trucks is a great opportunity to address
high-emitting vehicles and incentivize more funding towards
charging and refueling infrastructure. 

A focus on MHD infrastructure is important given the need to get
companies and fleets to transition to zero-emission. With potential
regulations on the horizon for a full fleet transition, those
looking to purchase a zero-emission truck need FCI and HRI options
in place. 

CALSTART encourages CARB to work with stakeholders regarding MHD
public charging or public/private charging locations. These
conversations are more important if the public, public/private
charging location would be inclusive of light-duty (LD) in addition
to MHD. Safety concerns, different infrastructure needs, and time
of charge requirements are all elements needing to be addressed
before construction on infrastructure begins so that the charging
location can scale up as needed in the future. 

CALSTART encourages CARB to work with stakeholders and
manufacturers/operators regarding LD charging in multifamily units.
Research in charging equity continue to show a lack of adequate
charging infrastructure in multifamily locations. Consideration of
reclassification from multifamily to non-residential for LCFS
purposes has been a topic of discussion regarding how to
incentivize more investments into charging installation and allow
benefits to be received by early investing companies and operators
who take larger risks with their investments. 

Conclusion: 
CALSTART appreciates the opportunity to submit public comment
regarding several of the topics CARB is looking to address in their
review of the LCFS program. Where we did not submit formal
comments, we encourage CARB to engage with stakeholder and industry
leaders and offer our services to arrange meetings for CARB staff.


The LCFS program continues to be one of the best drivers for
reduction of carbon in fuel and opportunities to incentivize and
promote investments in cleaner fuel and zero-emission
infrastructure. The basis of the program should be adopted by other
states in the country and CALSTART will continue to push for
multi-state adoptions based on the successes of California's LCFS
program. 

Thank you for your time and consideration. Please feel free to
reach out if there are any comments or questions. 

Orville Thomas
State Policy Director
CALSTART