Comment Log Display

Tuesday, August 27, 2024

Clerks' Office
California Air Resources Board
1001 I Street
Sacramento, California 95814

Subject: Please further strengthen the Low Carbon Fuel Standard --
Notice of Public Availability of Modified Text and Availability of
Additional Documents and/or Information for the Proposed Low Carbon
Fuel Standard Amendments

To Governor Gavin Newsom, CARB Chair Liane M. Randolph, and CARB
Board Members:

I am deeply concerned about the current state of California's Low
Carbon Fuel Standard (LCFS), the program that's supposed to
incentivize transition to "low-carbon" transportation, and,
therefore, am greatly appreciate that the California Air Resources
Board has released a proposed update to the LCFS. Disappointingly,
the revision 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." I implore you to take
immediate action to address the environmental injustices embedded
in the program.

Originally intended as a tool to combat climate pollution in the
transportation sector, the LCFS has been manipulated by powerful
industries, particularly Big Ag and Big Oil. It has become the
nation's largest and most lucrative pollution trading scheme for
factory farm biogas, perpetuating harmful practices rather than
serving its environmental objectives.

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," a false solution that has infected California's
climate policies. 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. Incentivizing the buildout of dirty factory farms
not only enables pollution but disproportionately harms low-income
communities and communities of color. Factory farms, predominantly
situated in these marginalized areas, inflict severe damage on air,
water, public health, rural economies, and overall quality of life.
Collecting methane from factory farm cesspits does nothing to
alleviate the massive harm mega-dairies and other large factory
farms do to these communities. I strongly 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.

Instead of doubling down on dirty factory farm gas, I demand a
future free from the clutches of Big Oil and Big Ag and to
prioritize Californians over corporate profits.

Thank you for your consideration of my comments. Please do NOT add
my name to your mailing list. I will learn about future
developments on this issue from other sources.

Sincerely,
Christopher Lish
San Rafael, CA