Comment Log Display

Dear Clerk of the Board,

My name is Angela Kurdyla, I live in San Francisco, and I am an
undergraduate student of Environmental Studies at the University of
San Francisco. 

It is my belief that the changes made in the "Third Notice of
Public Availability of Modified Text and Availability of Additional
Documents and Information" are not sufficient to implement the
"Proposed Low Carbon Fuel Standard Amendments." Changes made in the
"Third Notice..." do not sufficiently respond to the concerns of
the nonprofit groups, Food and Water Watch, Communities for a
Better Environment, and Growth Energy regarding carbon credit given
for the production of renewable hydrogen from the burning of
biomethane.

Renewable hydrocarbons are a necessary clean energy source for long
term energy storage as we shift away from burning fossil fuels.
However, the Board does not account for the implication crediting
renewable hydrogen production will have on large agricultural
animal feeding operations. Though I acknowledge the positive
incentive this amendment has to move away from fossil fuel
reliance, incentivizing fuel production in animal agricultural
operations will only increase the size of these GHG hotspots. In
2022, the agricultural sector accounted for 8% of state GHG
emissions with 70% of these GHG emissions deriving from livestock,
primarily dairy farms (California Air Resources Board, 2024). It is
my fear that encouraging biomethane production will increase
agricultural GHG emissions as agriculture operations see incentive
in expanding their operations. Methane digesters are now common
among large dairy farms as it is only large livestock feeding
operations that can produce a sufficient amount of manure to
benefit off renewable hydrogen production. Herd sizes of dairy
facilities grew roughly 3.7% in a year, moving against Biden's
Global Methane Pledge committing to a 20% reduction in herd sizes
(Skiff, 2024). While the nation should be transitioning away from
its dependence on livestock feeding operations, California is
moving backwards. 

"The Proposed Low Carbon Fuel Standard Amendments" if adopted, will
result in a nonuniform transition to better air quality. I urge the
California Air Resources Board to vote against the "Proposed Low
Carbon Fuel Standard Amendments." The state of California should
not jeopardize the air quality of our future for a fleeting
economic benefit to the livestock industry.


References:

California Air Resources Board. (2024, September 20). California
greenhouse gas emissions from 2000 to 2022.
https://ww2.arb.ca.gov/sites/default/files/2024-09/nc-2000_2022_ghg_inventory_trends.pdf

Skiff, S. (2024, February 21). New research reveals factory farm
manure biogas production harms environmental justice, fails to
achieve methane reduction targets, and worsens consolidation.
Friends of the Earth.
https://foe.org/news/factory-farm-manure-biogas-report/