Comment Log Display

The California Air Resources Board's proposed update to the Low
Carbon Fuel Standard doesn't go far enough.  Despite persistent
opposition from the environmental justice community, it continues
those parts of the program that provide financial support for
harmful practices, such as biofuel produced from virgin soy and
canola oil, and factory farm production of "biomethane."

* The proposal to remove credits for hydrogen produced from fossil
fuels is a positive step.  But delaying implementation of this
measure until 2030 means production of hydrogen from fossil fuels
will continue to receive financial rewards for another five-plus
years, thus incentivizing the harm we should be preventing.

* Biofuels produced from virgin soy or canola oil have major
negative consequences, including deforestation, and incentivizing
industrial agriculture that generates large amounts of greenhouse
gas and other pollution, and drives up food prices.  The proposed
revision acknowledges such problems, but continues to provide
credits for the production of biofuels that include up to 20
percent from these destructive sources.  And even this weak
restraint will not take effect until 2028.  Environmental justice
advocates have repeatedly called instead for caps on vegetable-oil
based biofuels.

* The proposed draft continues to provide credits for industrial
dairy "biogas."  This financial support continues to incentivize
the expansion of large-scale factory dairy farms, causing serious
harm to the health of surrounding communities, increasing the
greenhouse gases and pollution generated by the production of feed
for cows confined to barns; concentrated methane emitted by pools
of waste; the inevitable leakage of methane during storage and
transportation; and greenhouse gas emissions produced by combustion
of the product.  We urge CARB to phase out support for biomethane
as rapidly as possible.

* Unlike previous versions of the LCFS, the new proposal does not
require airlines to take any responsibility for the combustion of
fossil jet fuel, even for intrastate travel.  This is a step
backward, excluding a major source of greenhouse gases and
pollution from fossil fuel combustion.

In short, the Low Carbon Fuel Standards need to be further
revised.
Sincerely, 
Mary Flanagan