On 15 December, Bob Dinneen, RFA President and CEO, sent a letter to Mary Nichols,
Chairwoman of the California Air
Resources Board (ARB) and Susan Lapsley, Director of California's Office of Administrative Law (OAL), arguing that because ARB failed to respond to significant comments submitted by RFA and other stakeholders, under the California APA, OAL must disapprove the LCFS.