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Thank you again for the opportunity to comment on the workshop. In
summary, we support CARB maintaining a strong LCFS program so that
it may continue serving as a driver of innovation and greenhouse
gas reductions, including from pathways that will serve to address
one of the most potent and intractable climate change challenges -
N2O emissions. Accordingly, we encourage CARB to specifically:

•	Propose and adopt carbon intensity reduction targets no less than
those identified in Alternative C
•	Consider a ratcheting mechanism to capture additional greenhouse
gas reduction opportunities that may be available under the
program
•	Support California's access to RNG and replace imported fossil
natural gas by continuing to allow book and claim accounting for
projects anywhere in North America (as proposed in Alternative C)
•	Ensure that avoided N2O emissions are allowed in the program,
through at least 2045.
o	Should CARB choose to limit avoided methane accounting in the
future, as proposed in Alternatives A and B, make clear that
avoided N2O will be included in the program.

We look forward to CARB formally kicking off the rulemaking process
and continuing to participate in discussions about strengthening
the LCFS. Please do not hesitate to reach out if you have any
questions about Ductor or these comments.

Sincerely,



Bernard C. Fenner
CEO Ductor Corporation & President Ductor Americas, LLC

Original File Name: Ductor Americas Inc - LCFS comments.pdf

Date and Time Comment Was Submitted: 2022-12-20 21:09:16