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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.