then the programs will be awarded permits under both the Cap-and-Trade and the LCFS program. This is intentional. The Air Resources offers this as an incentive to encourage actions to lower carbon intensity under both the Cap-and-Trade and the LCFS. Second, those same principles should be extended to the Innovative Technologies for Crude Oil Production program outlined in the Proposed Rulemaking. Ant Innovative Technology that can achieve a sustained commercial breakthrough should be eligible for inclusion under the and the LCFS programs. Any decision to limit access to or eligibility under the LCFS program is counter-productive. It reduces the incentives to support the innovation and will ultimately harm the LCFS program. AWE supports the basic simultaneous access to the Cap and Trade (C&T) program and the Low Carbon Fuel Standard (LCFS). The Staff responses to issues raised by the Department of Finance underlines the important this consistency. The Staff states: LCFS and the Cap-and-Trade program are “The designed to complement one another. Investments made to comply with one of the programs will result in reduced compliance requirements for the other program. Reductions in the carbon intensity of fuel due to the LCFS reduce compliance obligations under the Cap-and-Trade Program. Similarly, selling cleaner fuels to comply with Cap-abd-Trade helps meet the requirements of the Air Resources Board: Notice of Public Hearing to LCFS.” (Title 17. California Consider a Low Carbon Fuel Standard, pg. 24) strongly supports this. The Staff properly finds that any program that AWE’s meets the requirements of both the Cap-and Trade and the LCFS should be recognized and benefit from both programs. Such programs should receive tradable permits under BOTH the Cap-and-Trade and the LCFS programs. This consistency is emphasized by the Staff as an important way to provide potentially important financial support for efforts undertaken to lower the carbon intensity of the fossil fuel sectors of the California economy.
then the programs will be awarded permits under both the Cap-and-Trade and the LCFS program. This is intentional. The Air Resources offers this as an incentive to encourage actions to lower carbon intensity under both the Cap-and-Trade and the LCFS. Second, those same principles should be extended to the Innovative Technologies for Crude Oil Production program outlined in the Proposed Rulemaking. Ant Innovative Technology that can achieve a sustained commercial breakthrough should be eligible for inclusion under the and the LCFS programs. Any decision to limit access to or eligibility under the LCFS program is counter-productive. It reduces the incentives to support the innovation and will ultimately harm the LCFS program. AWE supports the basic simultaneous access to the Cap and Trade (C&T) program and the Low Carbon Fuel Standard (LCFS). The Staff responses to issues raised by the Department of Finance underlines the important this consistency. The Staff states: “The LCFS and the Cap-and-Trade program are designed to complement one another. Investments made to comply with one of the programs will result in reduced compliance requirements for the other program. Reductions in the carbon intensity of fuel due to the LCFS reduce compliance obligations under the Cap-and-Trade Program. Similarly, selling cleaner fuels to comply with Cap-abd-Trade helps meet the requirements of the LCFS.” (Title 17. California Air Resources Board: Notice of Public Hearing to Consider a Low Carbon Fuel Standard, pg. 24) AWE’s strongly supports this. The Staff properly finds that any program that meets the requirements of both the Cap-and Trade and the LCFS should be recognized and benefit from both programs. Such programs should receive tradable permits under BOTH the Cap-and-Trade and the LCFS programs. This consistency is emphasized by the Staff as an important way to provide potentially important financial support for efforts undertaken to lower the carbon intensity of the fossil fuel sectors of the California economy.