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Dear Chairwoman Nichols and Mr. Corey,
I am writing on behalf of the American Biogas Council to express
our strong support for the Short‐Lived Climate Pollutant
Reduction Strategy Concept Paper. The Concept Paper provides an
excellent summary of the science and the urgency of reducing SLCPs
and a very good starting point for developing the strategy to
reduce SLCPs. We look forward to working with the Air Board and
other stakeholders to develop a strategy that will reduce SLCPs and
other pollution while helping to meet the state’s clean energy,
waste diversion and other important goals.
The American Biogas Council (ABC) represents over 200 businesses in
across the US, including over 3 dozen located in California and
dozens others doing business there, who are all dedicated to the
development of the biogas industry. Our member companies span the
entire biogas industry supply chain: project developers,
landowners, anaerobic digestion providers, waste water companies,
waste managers, utilities, financial firms and others.
The ABC reiterates and strongly supports these three main points
and associated sub‐points submitted by the Bioenergy
Association of California (BAC), one of our members: 
A. Strong Support for the Concept Paper Overall
The ABC strongly supports the Concept Paper overall and applauds
the Air Board for producing an excellent first draft. We are
especially impressed with the very strong summary of the science,
the clear message throughout the Concept Paper about the urgency of
reducing SLCPs, cross‐sector and integrated strategies to
reduce SLCPs.
B. Immediate Research Needs
The Concept Paper points out in several places where additional
research and demonstration is needed. ABC supports the BAC
recommendation that the Air Board and other agencies should begin
immediately to address the following important research needs:
1. Need to Quantify Lifecycle Emissions and Reductions from Organic
Waste, including Different End Uses.
2. Need a lifecycle analysis of the GHG/SLCP emissions and
reductions from forest fuel treatments and their end uses.
3. Need to quantify emissions reductions from organic soil
amendments such as biochar, biosolids,
digestate and compost.
C. Recommended Strategies to Reduce SLCPs
The ABC also supports the BAC recommended strategies that the Air
Board should add:
1. Align GGRF and other funding with SLCP reduction priorities.
2. Need to change utility processes and incentives.
3. Need a cross sector strategy to increase the use of renewable
gas, such as a Renewable Gas Standard.
Like the BAC, we urge the Air Board to propose a policy that
requires the increased production and use of renewable natural gas,
like the Renewables Portfolio Standard (RPS) in the electricity
sector and the
Low Carbon Fuel Standard in the transportation sector. More than 25
percent of California’s greenhouse gas emissions are from the use
of fossil natural gas (not including leaks). Increasing the
production and use of biogas processed into renewable natural gas
would reduce SLCPs upstream, reduce fossil fuel emissions, and
provide organic soil amendments such as biochar and biosolids.
Increasing renewable gas production can reduce greenhouse gas
emissions by tens of millions of metric tons per year.
Incentives are powerful tools for piloting and demonstrating new
technologies and helping to commercialize an industry, but they do
not provide the long‐term market demand or certainty needed
to truly transform an industry. Just as California needs the RPS
and LCFS to move to renewable energy and low carbon fuels, it needs
a policy to significantly expand the production and use of
renewable gas.
The American Biogas Council urges the Air Board to recommend, in
the SLCP Strategy, the adoption of a Renewable Gas Standard or
other policy that requires California to increase the percentage of
renewable gas, particularly biogas, produced and used in
California. The path ARB proposes to take is at the forefront
nationally on these issues. No other jurisdiction has put on the
table anything nearly as comprehensive in the scope of the GHG
issues they propose to address. Nor has an executive agency in any
other state so boldly proposed integrated strategies that cross
multiple agencies within the executive branch, as well as action
from the legislature. This is bold leadership, and we support ARB’s
direction.
We look forward to working with the Air Board to develop and
implement a successful strategy to reduce SLCPs. The Concept Paper
is a great start.  


Sincerely,
Patrick Serfass
Executive Director
American Biogas Council