Al Collins Senior Director Regulatory Affairs – 1701 Pennsylvania Ave NW, Suite 800 Washington, DC 20006 Phone: 202-857-3000 Via electronic submittal: http://www.arb.ca.gov/lispub/comm/bclist.php August 30, 2018 Clerk of the Board Air Resources Board 1001 I Street Sacramento, CA 95814 Subject: Comments to the Comments to Proposed Second 15-Day Modifications to the Low Carbon Fuel Standard and the Carbon Capture and Sequestration Protocol Dated August 13, 2018 Dear Clerk of the Board: to provide comments Occidental Petroleum Corporation (“Occidental”) appreciates this opportunity to the California Air Resources to the Low Carbon Fuel Board’s (“CARB”) proposed amendments Standard and the Proposed Second 15-day Modifications to the Carbon Capture and (“LCFS”) Sequestration Protocol August 13, 2018. (“Protocol”) dated Occidental values and amendments to the LCFS and supports CARB’s leadership role in developing developing a protocol for carbon capture and sequestration. CARB staff has been active and engaged in working with stakeholders to craft language that will ensure that GHG reductions from CCS are real, permanent, quantifiable, verifiable, and enforceable. The LCFS revisions and Protocol will appropriately incentivize involvement and aid California in its pursuit of mid-century climate goals. comments to several LCFS and Protocol provisions are attached. Given the Occidental’s specific complexity of the documents, it is a testament to the tremendous effort that the CARB staff has committed to the process that the remaining issues have been narrowed to those reflected in Attachment A. We hope these comments prove helpful, and we look forward to continued engagement with the CARB staff as we move into the implementation phase of the Protocol. Should you have any questions, I may be reached at (202) 857-3000. Best regards, Al Collins Al Collins Sr. Director Regulatory Affairs – Encl.: Attachment A
Al Collins – Senior Director Regulatory Affairs 1701 Pennsylvania Ave NW, Suite 800 Washington, DC 20006 Phone: 202-857-3000 Via electronic submittal: http://www.arb.ca.gov/lispub/comm/bclist.php August 30, 2018 Clerk of the Board Air Resources Board 1001 I Street Sacramento, CA 95814 Subject: Comments to the Comments to Proposed Second 15-Day Modifications to the Low Carbon Fuel Standard and the Carbon Capture and Sequestration Protocol Dated August 13, 2018 Dear Clerk of the Board: Occidental Petroleum Corporation (“Occidental”) appreciates this opportunity to provide comments to the California Air Resources Board’s (“CARB”) proposed amendments to the Low Carbon Fuel Standard (“LCFS”) and the Proposed Second 15-day Modifications to the Carbon Capture and Sequestration Protocol (“Protocol”) dated August 13, 2018. Occidental values and supports CARB’s leadership role in developing amendments to the LCFS and developing a protocol for carbon capture and sequestration. CARB staff has been active and engaged in working with stakeholders to craft language that will ensure that GHG reductions from CCS are real, permanent, quantifiable, verifiable, and enforceable. The LCFS revisions and Protocol will appropriately incentivize involvement and aid California in its pursuit of mid-century climate goals. Occidental’s specific comments to several LCFS and Protocol provisions are attached. Given the complexity of the documents, it is a testament to the tremendous effort that the CARB staff has committed to the process that the remaining issues have been narrowed to those reflected in Attachment A. We hope these comments prove helpful, and we look forward to continued engagement with the CARB staff as we move into the implementation phase of the Protocol. Should you have any questions, I may be reached at (202) 857-3000. Best regards, Al Collins Al Collins Sr. Director – Regulatory Affairs Encl.: Attachment A
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