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Chair Randolph and Committee:

The California Air Resources Board (CARB) has shown that it
understands that to promote a cleaner environment effectively and
quickly RNG is an essential component of the Low Carbon Fuel
Standard (LCFS) program and NGVAmerica appreciates CARB leadership
in this.

U.S. Gain is a leading producer of Renewable Natural Gas with over
40 production projects from a variety of feedstocks including
agricultural, landfills and wastewater treatment facilities. We are
diversified and vertically integrated in all aspects of the energy
supply chain, enabling access to the cleanest fuel and renewable
energy, at the best value. 


U.S. Gain is active in all forms of alternative fuels to decrease
harmful transportation emissions including battery electric
charging, hydrogen fueling for fuel cell electric vehicles and
renewable natural gas. We are also actively working with our sister
company U.S. AutoForce, with 8 locations in California,  to
decrease emissions with our operations. 

As a member of NGVAmerica, U.S. Gain supports their endorsement of
strategies that promote the use of zero emission vehicles (ZEV),
near-zero emission vehicles and a transition to low and net
negative carbon transportation fuels such as renewable natural gas,
and eventually hydrogen. We understand there is no one solution to
the pressing environmental issues facing the transportations
sector. CARB should move quickly to deploy those technologies and
solutions that are readily available, maximize cost-effective
emission reductions, and provide a real pathway to carbon neutral
or carbon-negative emissions.
Converting medium- and heavy-duty (M/HD) vehicle transportation
networks to low NOx trucks operated on RNG provides a readily
available, proven and cost-effective solution to accelerate the
transition to a low-carbon transportation future. Further,
dedicating program resources to cleaner alternative fuel
technologies that are available now will significantly and
immediately benefit all communities by maximizing the displacement
of older, higher emitting diesel trucks and buses, including those
higher emitting vehicles that operate in communities that are
underserved by current transportation options.

Near-zero engines operated on RNG produce at least 90% less NOx
than the cleanest diesel engines and operate at virtually zero NOx
emissions (0.02 g/bhp-hr or less). In California RNG is used to
fuel low NOx vehicles providing reduced life cycle emissions of
greenhouse gases (GHG) that in some cases can be net zero or even
carbon-negative.

CARB data from the LCFS for Q3 2021 confirms the energy weighted
carbon intensity (CI) value of California's RNG vehicle fuel
portfolio is below zero at -62.7 gCO2e/MJ (negative CI for last 5
reporting quarters). California fleets that fueled with bio-CNG in
2020 achieved carbon negativity in 2020 for the first time ever,
with an annual average CI score of -5.845 gCO2e/MJ. Renewable CNG
(dairy gas) is now close to -600 gCO2e/MJ. Additional information
may be found at the following link:
https://ww2.arb.ca.gov/resources/documents/lcfs-pathway-certified-carbon-intensities.

U.S. Gain believe that CARB must continue to include and promote
the use of RNG low NOx trucks for the near term and beyond to
reduce emissions from the transportation sector, especially in
disadvantaged communities that have been relegated to diesel
solutions while we wait on the EV industry to commercially mature.
Some of the issues with M/HD ZEVs include:
• Vehicles can be ordered, but cannot be delivered
• Small-scale pilot service basis only today
• Substantial challenges whether duty cycles can meet business
needs
• Limited service networks
• Cost of ZEV technologies substantially higher than non-ZEV
technologies
• Affordability remains a significant barrier to large-scale
adoption
• Little charging/fueling infrastructure exists
• Electrical distribution system upgrades required
• Power/fuel supply to support widespread deployment will take many
years to develop

Low NOx vehicles with the potential of carbon net zero and even
carbon negative emissions with RNG are:
• Commercially demonstrated and available today
• Sufficient fueling infrastructure that is largely funded by the
private sector
• 90% cleaner than diesel trucks on NOx (without requiring
after-treatment apparatus)
• 100% elimination of diesel particulate matter emissions
• When fueled by RNG, can provide substantial GHG emissions
reductions
• More cost-effective than ZEV trucks, allowing limited incentive
funds to stretch further
• Addresses elements of the transportation sector that are hard to
electrify
• Enables a diversity of effective technology/fueling solutions
• Fueled with RNG that is produced from domestic, renewable,
plentiful feedstock
• Supports sustainability goals of organizations and fleets
Moreover, the salient points to promote the use of RNG include:
• The immediate reduction of fugitive methane emissions is
necessary to rapidly reduce the impacts of climate change
• Waste generators including livestock operators can gain a
sustainable outlet for their waste
• Animal manure can be collected on a single large farm or combined
from several "cluster" farms and delivered to a single anaerobic
digester for RNG production
• If manure is stored in open lagoons that emit methane, moving it
to enclosed digesters prevents those emissions
• Addresses agricultural waste and emissions to help offset costs
thereby reducing pressure on food prices and farmers
• The RNG produced also displaces fossil NG that would have been
consumed by NG vehicles, thereby reducing CO2 emissions
• Avoided methane emissions and displaced fossil CO2 emissions can
produce large reductions in carbon intensity • The California Air
Resources Board's assessment shows that RNG produced from dairy
waste has one of the lowest carbon intensity (CI) ratings of any
transportation fuel • RNG for transportation can reduce greenhouse
gas emissions up to 283%, with an average of 51% reduction (varies
by feedstock)

Real World Experience

Recently the California South Coast Air Quality Management District
(SCAQMD) responded to communications from Environmental Justice and
Environmental Health organizations objecting to the use of low NOx
trucks in the heavy-duty vehicle sector. The SCAQMD response letter
states:
"As the agency responsible for clean air in the greater Los Angeles
area we have a statutory obligation to take all reasonable and
feasible steps to reduce emissions. We face a rapidly approaching
hard legal deadline in 2023 to meet the 1997 ozone standard, and
2031 for the 2008 ozone standard. The only way to get there is a
massive push for cleaner heavy-duty trucks - the largest source of
smog-forming emissions in our region - as soon as possible. While
the amount of emission reductions needed to attain clean air
standards is daunting, it would be irresponsible for our agency to
effectively throw up our hands and not explore all options for
reducing emissions now. Near-zero emission (NZE) technology has
been commercially demonstrated and is available today, has
sufficient fueling infrastructure that is largely funded by the
private sector, and is at least 90% cleaner than new diesel trucks
on NOx and 100% cleaner on cancer-causing diesel particulate
matter. When fueled by renewable natural gas, these vehicles can
also provide substantial greenhouse gas emission reductions.
Further, these vehicles are far more cost-effective than ZE trucks,
allowing limited incentive funds to stretch further. Given these
benefits, it is disturbing that you advocate for investments only
in technologies that are not yet ready for prime time, a position
that would leave our residents no option but to continue to suffer
the ill effects from diesel exhaust for years to come."

Amazon has ordered thousands of Classes 6 through 8 trucks,
choosing low NOx vehicles because they would not buy diesel trucks
and could not buy electric trucks now or in a reasonable timeframe.
UPS, WM, Republic Services, Fort Collins Transfort Buses, Denver
International Airport Buses and equipment, Los Angeles World
Airports Buses, City of Los Angeles, City of Fresno Transit, LA
Metro Transit, New York's Hunts Point fleet Industries and many
other fleets have chosen low NOx trucks as the only available
non-diesel heavy-duty truck that outperforms other alternative
technologies in all aspects of vehicle operation.

To support low NOx markets in the United States, Asia, Europe,
South America and elsewhere, Cummins has initiated a worldwide low
NOx engine division to fulfill the demands for immediate diesel
alternatives across the world. In addition to 3 heavy duty low NOx
engines, they are bringing forward a new heavy-duty 15L engine that
provides the power and performance of diesel and that is 500 pounds
lighter and more efficient. Also, Hyliion is in the final stages of
field testing its plug-in hybrid electric/CNG Class 8 truck that is
scheduled to be commercially available in 2023.

As is evidenced in the above paragraphs, low NOx vehicles are
growing in the M/HD truck market, especially as new technology is
introduced, EV technology is delayed, cleaner engines are mandated
and diesel prices continue to climb. It should be noted that using
the AFLEET calculations, low NOx trucks are truly virtually zero
since it takes only 1.05 low NOx trucks to equal the NOx tailpipe
emissions reductions of a battery electric (BE) short-haul truck.
When the range/duty cycle issues are factored in (may take more
than one BE truck/bus to replace a diesel or low NOx truck/bus),
the cost-effectiveness of using electric vehicles is a significant
issue.

Investments in RNG-fueled trucks and transit buses accessing ports,
cities, and densely-populated neighborhoods are the most immediate
and fiscally-responsible investment to clean our air and combat
climate change. Communities get more clean vehicles having greater
clean air and climate impact for the money with RNG than with any
other alternative fuel option, especially electric. No other
transportation fuel is as sustainable, adaptive, and competitive
across all applications and vehicle classes.

Heavy-duty low NOx trucks are not demonstration science projects;
they are proven, scalable, and on U.S. roads today. We will not
meet emissions reductions goals or timeframes without using RNG.

Reduce Emissions Now and in the Future

More than four of every ten Americans live in communities with
dangerously dirty air. According to the American Lung Association,
over 135 million people are living in places with unhealthy levels
of ozone or particle pollution. And the burden of living with
unhealthy air is not shared equally; people of color are over three
times more likely to be breathing the most polluted air than white
people.1

U.S. Gain urges CARB to continue to support the development of
dairy digesters and the use of dairy biomethane in the Low Carbon
Fuel Standard and other programs. Reducing methane emissions from
dairies is critical to achieve the state's overall climate goals
and using that biomethane in heavy duty trucks that replace diesel
trucks also provides enormous benefits for air quality. Continuing
to support dairy digesters is also required by SB 1383 (Lara, 2016)
and multiple other laws in California.
Low NOx engines are proven, cost-effective and available today for
medium- and heavy-duty vehicles. Moreover, because RNG is used,
life cycle greenhouse gas emissions from low NOx vehicles are
reduced further. Fueling with RNG also creates new economic
development for energy created from wastewater treatment,
landfills, animal waste and other methane sources and significantly
increases air quality by reducing the amount of methane released.
We strongly believe that RNG-operated low NOx vehicles should not
just be "allowed" but must be promoted in the CARB LCFS program if
emissions reductions are to occur in any reasonable timeframe.
Statutory requirements are pressing on California and CARB needs
solutions that work now to decarbonize and clean California's
environment. Therefore, we request that RNG-operated low NOx trucks
be prominent in CARB's strategies as an immediate pathway to a zero
emission future.

Thank you for your consideration, and please contact me or with any
comments or questions.

Kind regards, 

Lynn Lyon

Director of Sustainable Transportation
U.S. Gain, a U.S. Venture Company