Comment Log Display

In addition to the attached document which reflects the views of
myself and the American Biogas Council, I would like to address the
brilliance that is California's LCFS.

California's LCFS is the first market-based regulation that
incentivizes clean fuel producers based upon HOW clean the fuel
they produce is. This is genius. It has led folks to find an
unregulated industry and clean it up. Prescriptive regulations are
effective, but they cannot do this. Market-based regulations fill
the gaps in prescriptive regulations. To punish clean fuel
producers who exploited this opportunity and operate within the
scientific, calculated bounds of California's LCFS would be
detrimental to the legitimacy of opportunities presented by this,
and other market-based regulations.

People quite often neglect the feasibility of biogas-electricity.
Unlike RNG, it is favorable for small farms, with less of an
incentive to increase the size of the farm. To truly solve the
problems I've read through requires that the EPA enable
biogas-electricity projects to generate the same D3 RINs. Even with
this being said, I encourage you to view the size of dairy farms
that have installed an AD system. It surprised me. This is NOT a
CAFO driver.

To suggest that biogas subsidizes dairy neglects the mechanisms put
in place by CA-LCFS that drive prices down as credit production
exceeds deficit production. The dairy opportunities are
short-lived. The manure gold rush will be over soon. Let's not over
react and destroy this effective regulation.