Comments to the CA Air Resources Board on Renewable Electricity in the Low Carbon Fuel Standard (LCFS)

Comments to the California Air Resources Board (ARB) regarding potential changes to how electricity used as a transportation fuel is treated in the ARB’s Low Carbon Fuel Standard (LCFS) Program (pursuant to California Assembly Bill AB 32 and the Governor’s Executive Order S-01-07). These comments pertain to the use of renewable electricity as a transportation fuel and the associated verification measures required to ensure exclusive use of renewable electricity. Specifically, these comments address topics and questions posed on slides 5 and 21 from the December 2, 2016 Workshop on Grid and Renewable Electricity and pages 4 and 13 of the November 23, 2016 Staff Discussion Paper.