| Comment | Funding biogas production under the Low Carbon Fuel Standard (LCFS)
is harmful and incentivizes the consolidation
and growth of the factory farming industry. Every year, this
industry forces billions of animals to suffer in horrendous and
cruel conditions. It creates pollution that uses fossil fuel and
accelerates the climate crisis. I would choose my taxpaying dollars
to fund. sustainable and clean energy and I would never support the
business of factory farming. To begin addressing substantial
harms, I implore you to implement the following reforms to the
LCFS:
1. Eliminate "avoided methane crediting" in 2024.
2. Address inaccuracies in the Life Cycle Assessment that ignore
associated up and downstream greenhouse gas emissions from factory
farm gas production.
3. Remove the 10-yr grace period for factory farming gas production
4. Stop double counting by allowing factory farming gas projects
that have been paid for to also be claimed by other programs. This
is underhanded and wrong.
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