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Dear Chair Randolph,
 
We would like to support the comments offered by Newtrient LLC on
behalf of the dairy industry in response to the February 22, 2023,
Public Workshop regarding potential changes to the Low Carbon Fuel
Standard (LCFS).
 
Newtrient applauds the leadership the California Air Resources
Board (CARB) is taking on climate change and appreciates being a
part of this important dialogue surrounding potential changes to
the Low Carbon Fuel Standard (LCFS). The dairy industry has
answered the call to action and is embracing environmental
responsibility - from family farms in California, to farms across
America. By installing and utilizing biogas systems, farms are
offering practical solutions to the challenges CARB seeks to
address.
 
We would like to highlight our support of the following: 
·         We encourage CARB to adopt higher Carbon Intensity (CI)
reductions.
·         We urge CARB to reconsider elimination of Book and
Claim.
·         We strongly oppose phasing out avoided methane emission
crediting.
 
Additionally, we would ask that CARB do the following:
·         Advocate For Ongoing Investment in Dairy Digester Methane
Capture and Beneficial Use
·         Update GREET Modelling
·         Oppose RNG Market Use Limitations
·         Support Market Mechanism
·         Reject Calls to Regulate Dairies.
 
We appreciate CARB's efforts to lead a robust stakeholder process
ahead of formal rulemaking. We look forward to continuing to
partner with the California dairy industry, CARB, and other
stakeholders in the successful achievement of the State's climate
goals, particularly the world leading short-lived climate
pollutants (SLCP) target and programs. Greenhouse gas ("GHG")
emissions have a global impact, and it is important that CARB
demonstrate that its programs can harmonize environmental goals and
protect the state's economy. This is particularly true of local
economies in the disadvantaged communities the State says it will
prioritize. California's dairy farm families and developers are
striving to develop projects that not only reduce potent SLCP
emissions, but also create opportunities for economic development
that helps protect jobs and improve baseline environmental
conditions in these communities.
 
Thank you for your consideration of these comments.

Original File Name:

Date and Time Comment Was Submitted: 2023-03-16 18:44:33