Comment Log Display

2134 E. Mineral King Ave
Visalia, CA 93292
559-667-9560
April 21, 2025
Ms. Rajinder Sahota
Deputy Executive Officer - Climate Change & Research
California Air Resources Board
1001 I Street
Sacramento, California 95814
Re: California Bioenergy's Comments on CARB's April 4th, 2025 Third
15-Day Amendments to the Low Carbon Fuel Standard Regulation
Dear Ms. Sahota,
Thank you for the opportunity to provide these comments to
California Air Resources Board (CARB) relating to the Third 15-Day
Amendments to the Low Carbon Fuel Standard (LCFS) Regulation
released on April 4th, 2025. California Bioenergy LLC (CalBio) is
appreciative of CARB's efforts over the past several years to
develop the LCFS program into one of the most impactful policies to
support the transition from fossil fuels to lower carbon
alternatives.
Founded in 2006, CalBio works closely with California dairy farm
families along with local, state, and federal agencies to reduce
methane emissions. CalBio is committed to enhancing environmental
sustainability for all Californians through our digester projects
which produce carbon-negative renewable natural gas and
electricity.
CalBio urges CARB and OAL to adopt the latest 15-Day Rulemaking
Package as amended
We write these comments to commend CARB's continued leadership in
advancing policies that address climate change, promote public
health, and stimulate economic growth. The LCFS has been
instrumental in facilitating the development of dairy digesters.
According to data from the California Department of Food and
Agriculture (CDFA), dairy digesters in California are on track to
collectively reduce approximately 2.4 million metric tons of
CO₂-equivalent (MTCO₂e)1 emissions annually--marking
significant progress toward achieving the 40% methane reduction
target set by SB 1383.
1 California Department of Food and Agriculture Dairy Digester
Research and Development Program - Program-Level Data (Updated
January 8, 2025)
https://www.cdfa.ca.gov/oefi/DDRDP/docs/DDRDP_Program_Level_Data.pdf


Also important to consider are the environmental, health, and
economic benefits of the LCFS program. Since its inception, the
program has achieved a reduction of approximately 13% in the carbon
intensity of transportation fuels, displacing over 30 billion
gallons of petroleum fuel and reducing emissions equivalent to
removing 6.4 million cars from the road. This reduction in fossil
fuels translates directly into public health benefits. CARB
estimates that from 2024 to 2046, the LCFS will result in $5
billion in savings from avoided health outcomes, primarily through
enhanced air quality.


While we believe there are aspects of the regulation which could be
improved - namely the concerns we had raised in previous around
data substitution methodologies in Section 95491.2, we believe CARB
and the Office of Administrative Law (OAL) should adopt the final
draft regulation of the LCFS Program as written.34 Given the
growing LCFS credit bank, it is imperative that the effective date
of the regulation be applicable to Q1 2025 dispensing fuel
reporting activities such that the LCFS Carbon Intensity Benchmarks
stated in Table 2 and Table 3 of the Proposed Regulation remain in
full effect.

At a time where ambitious climate action is needed now more than
ever, the LCFS remains the primary example for other states and the
world to follow. We appreciate CARB's dedication to environmental
stewardship and stand ready to support the continued success of the
LCFS.

Sincerely,
Andrew Craig
Vice President, Greenhouse Gas Programs
California Bioenergy LLC

2 CARB updates the Low Carbon Fuel Standard to increase access to
cleaner fuels and zero-emission transportation options
https://ww2.arb.ca.gov/news/carb-updates-low-carbon-fuel-standard-increase-access-cleaner-fuels-and-zero-emission
3 CalBio Comments on CARB's Proposed Tier 1 Simplified Calculator
for Biomethane from Anaerobic Digestion of Dairy and Swine Manure
released December 19, 2023
https://www.arb.ca.gov/lists/com-attach/6968-lcfs2024-VTYCZQFsV2ZRPgBv.pdf
4 California Bioenergy's Comments on CARB's April 10th, 2024 Public
Hearing on the Low Carbon Fuel Standard
https://ww2.arb.ca.gov/form/public-comments/submissions/11571