Comment Log Display

LCFS Method 2 Fuel Pathway Applications #222

There are at least two major faults with this carbon intensity
proposal by CalBio.

One, the LCFS requires a much more complete and thorough well to
wheels analysis. The applicant proposes to begin their analysis
with manure already sitting in a lagoon and releasing methane. But,
that event does not happen in isolation. That event does not have
to happen at all. It must be considered with the whole series of
events and choices relating to the standard operations at this
cluster of factory dairies.

Second, this proposal requests carbon credits for the produced CNG
which includes a large negative credit for the methane emissions
avoided. Their calculation then results in a large negative carbon
intensity for the CNG fuel. But, there is no opposite debit for the
methane that is released by these dairies from their other manure
handling practices together with the enteric emissions from the
cows themselves. All so-called waste products from these cows,
whether they be liquid, solid, or gaseous must be considered for
their CO2e. All other emissions of green house gases at the dairy
must also be added if there is to be a credit for emissions which
are avoided.

Therefore, it is expected that this proposal will be sent back to
Cal Bio for a more complete and accurate analysis reflecting the
requirements of the LCFS and other general accounting principles
under AB32.