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To quote the vice president for operations at Dynamic Renewables, a
Wisconsin-based company that operates digesters in the Midwest
where the LCFS is driving factory farm expansion, "More cows and
more manure means more energy." (Erin Jordan, 'More Manure Means
More Energy': Iowa Dairies with Biogas Digesters Are Growing Their
Herds, which Concerns Water Quality Advocates, Gazette (Nov. 3,
2024),
https://www.thegazette.com/agriculture/more-manure-means-more-energy-iowa-dairies-with-biogas-digesters-are-growing-their-herds-which-c/).
The evidence is unavoidable that CARB's decision to allow factory
farms to see large profits from the LCFS under the avoided methane
crediting policy is counterproductive and the definition of unjust
climate policy. As much as staff wish to ignore this, they cannot
overcome reality. 

And the proposal today attempts to lay waste to CARB's statutory
obligations under SB 1383. As staff's presentation reiterated this
morning, the LCFS works to "decarbonize our transportation sector."
 Not the dairy sector. By pushing methane mitigation in agriculture
into the LCFS as your means of meeting 1383, you ignore the obvious
and staff's own admissions about how capture in one sector used to
meet legal obligations in another works. 

Finally, the resolution offers a timeline for 1383 regulations that
is, on its face, at odds with the statutory text. The resolution
calls for staff to implement regulations "starting in 2030."  SB
1383 obligates CARB to meet the 40% reduction "by 2030." You cite
the statute in the resolution, but direct staff to openly flout the
timeline the legislature required. The fix is clear and required by
law: CARB must now prioritize 1383 regulations to reduce manure
methane emissions and stop using the LCFS and avoided methane
crediting to reward factory farms for polluting the climate and
communities across the country.