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Dear Dr. Laskowski:

Thank you for the opportunity to comment on the February 22, 2023
Public Workshop to Discuss Potential Changes to the Low Carbon Fuel
Standard (LCFS). The LCFS is one of the most powerful climate
change policies in the world, and it uniquely supports a wide array
of innovative low carbon fuel production pathways. This can include
pathways that significantly reduce emissions of N2O, such as
projects that Ductor develops. We encourage you to strengthen the
program through the amendment process to ensure it continues
playing this unique role - delivering deep emission reductions from
expected, and unexpected, sources. In particular, we offer the
following recommendations:

•	Strengthen carbon intensity reduction requirements to align with
levels needed to achieve outcomes in the 2022 Final Scoping Plan,
including a target of at least 35% carbon intensity reduction by
2030.
•	Include a step-change in carbon intensity in 2024 to account for
the current oversupply of credits and develop a one-way ratchet
mechanism to provide certainty needed to develop new, low carbon
fuel pathways, capture additional opportunities for carbon
intensity reductions, and ensure the strength of the program on an
ongoing basis.
•	Avoid changes to biogas pathway crediting that lead to high
credit price spikes, including reducing book-and-claim
opportunities for out-of-state biogas, which provides an important
source of fuel and credits under the program. 
•	Should CARB restrict book-and-claim of biogas, allow biogas to
provide book-and-claim energy for all zero emission vehicle fuels
equally (hydrogen production and electricity production) and as
process energy to other fuel pathways.
•	Ensure that avoided N2O emissions are fully and completely valued
in the program and calculators.
•	Update the Tier 1 calculator for dairy and swine manure to apply
to all manure pathways, including biogas from poultry manure, and
ensure accounting includes avoided N2O emissions and beneficial
byproducts like organic and sustainable fertilizers. 

Original File Name: Ductor LCFS comments_2.22.23 Workshop final.pdf

Date and Time Comment Was Submitted: 2023-03-15 14:25:27