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I live in the San Joaquin Valley of California and have been
here for over 30 years and my whole life in California.  I
like the progress that is being made to reduce emissions by
capturing methane and replacing diesel and gasoline as a
transportation fuel.  The LCFS credits structure has been a
valuable tool to incentivize investment to build methane digesters
not only in California, but accross the United States.  My
concern is that the projects are so successful that they are
starting to generate significant LCFS credits now that the projects
are starting to produce gas and gettting their pathways in
place.  Reviewing  the statistics on your website, the
fossil natural gas has been displaced by landfill gas and the
livestock gas over time.  Based upon the credit values, the
trend will continue with the landfill gas to be displaced by the
livestock gas going forward which will create more credits for the
same level of diesel gallon equivalents being used.  We will
see some organic growth as vehicles are converted to RNG from
diesel in terms of the overall percentage.  The result is that
between credits generated from renewable diesel and the livestock
gas coming onboard with much from out of state, the number of
credits are exceeding the deficits and LCFS credit prices are
falling from over $200 to less than $120 over the past few
months.  Much of the gas is from outside the state of
California which do nothing towards reaching our goal to reduce
methane emissions by 40% by 2030 in California.  These lower
credit values may lead to less investment to cover capital costs
and operating costs which may ultimately cause failure to meet the
methane reductions requirements.  The question for you is how
do we increase the conversion to to RNG from diesel and at the same
time keep the incentive in place to capture livestock methane
emissions with digester projects to continue to work towards that
while not flooding the market of LCFS credits from landfill and
livestock gas as well as other renewables coming in from outside of
California.  They are getting the economic benefit from the
credits, but not contributing towards better air quality in
California.  I pay a premium in fuel prices to support these
programs, but would also like them to benefit my air basin with
better air quality rather than my funds going to out of state
producers.   The export of credit values to RNG suppiers
outside of California from people like me paying higher prices at
the pump doesn't seem equitable.  I could see the 1% RNG
changing suppliers with over all carbon intensity being reduced buy
maybe not reducing methane and possibly no change in tailpipe
emissions unless we mandate higher convertion to CNG vehicles from
diesel/gasoline.
Thanks for your time and efforts.
Jonathan