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I have worked as a scientist for over 50 years and have created
many computer models. The most important thing you learn about
modelling is that if you start with bad assumptions, you end up
with incorrect conclusions. The crucial bad assumption in the LCFS
is that fuels created from sources of recent biological origin do
not harm the climate and are thus sustainable. This fallacy is
easily exposed by the fact that the atmosphere does not know if a
specific CO2 molecule comes from a plant that died a million years
ago or just last week. It still has an atmospheric lifetime of 100
years. LCFS crediting for dairy manure digester gas(DMG) and
renewable diesel(RD) are two examples of this fallacy. While CARBOB
has a CI of 100 g CO2e/MJ, RD has a CI=50, DMG CI=-150 while wind
and solar electricity have CI=10 while generating no CO2 during
operation. How can a technology that generates no CO2 be worse for
the climate than DMG which generates the same amount of CO2/MJ as
fossil natural gas when burned? 
As we heard in the CARB presentation today, we cannot solve the
climate crisis by continuing to combust carbon. LCFS must quickly
phase out all credits for carbonaceous fuels and reserve future 
credits only for electric transportation based on wind and solar PV
electricity. CARB staff has done a lot of good work here, but these
two issues require them to go back to the drawing board. I urge the
Board to reject this proposal. Thank you.