First Name: | Staff |
---|---|
Last Name: | Submittal |
Email Address: | Helpline@arb.ca.gov |
Affiliation | Leadership Counsel for Justice and Accou |
Subject | subject of comment |
Comment |
Leadership Counsel for Justice and Accountability RE: Comments on the Recirculated Draft Environmental Analysis for the 2022 Draft Scoping Plan Dear Board Members and Staff of the California Air Resources Board ("CARB"): Leadership Counsel for Justice and Accountability submits these comments on the Recirculated Draft Environmental Analysis ("RDEA") for the 2022 Draft Scoping Plan Update ("Draft Scoping Plan"). CARB must exclude polluting fuels from the Low Carbon Fuel Standard ("LCFS") while increasing its stringency. The RDEA proposes increasing the stringency of the LCFS.1 This proposal echoes proposals by CARB staff in recent workshops on the upcoming LCFS rulemaking, and appears to be in response to Governor Newsom's call for increased stringency of the LCFS.2 We are not opposed to increased stringency in concept. However, there are likely consequences of taking this action in isolation that are deeply concerning. Currently, the LCFS includes not only decidedly carbon neutral transportation fuels, such as electric vehicles powered by solar and wind, but also polluting fuels such as dairy manure derived biomenthane, otherwise known as factory farm gas. In fact, factory farm gas is considered the most carbon negative fuel.3 The methodology that generates this outcome is currently subject to significant scrutiny and skepticism due in part to an incomplete and inaccurate lifecycle analysis of factory farm gas.4 In particular, it treats liquified manure storage, a profit-maximizing practice that results in significant greenhouse gas emissions, as the baseline. The methodology also excludes enteric emissions and post-digestion emissions from manure along with other GHG emissions associated with the production of factory farm gas. A full accounting of these emissions undermines the assertion that production of factory farm gas results in greenhouse gas emissions reductions. For these reasons, along with myriad negative local air and water quality impacts, these polluting fuels should be excluded from the LCFS. These methodological issues are of particular importance here because a likely outcome of increasing the stringency of the LCFS would be an increased demand for supposedly carbon negative fuels and the credits they currently generate for deficit holders to purchase. Without a true accounting of the net carbon emissions from industrial dairies and digesters, or excluding this fuel altogether, increasing the stringency of the LCFS would likely have the inverse effect that it intends: an increase in carbon emissions associated with the production of transportation fuels. For these reasons, CARB must exclude factory farm gas from the LCFS. The RDEA should be revised to increase the stringency of LCFS, in line with Governor Newsom's letter, while excluding fuel pathways that would undermine that goal. Respectfully Submitted, Leadership Counsel for Justice and Accountability Food & Water Watch Animal Legal Defense Fund The Center for Food Safety 1 RDEA at 22. 2 Governor Gavin Newsom's Letter to CARB. July 22, 2022. Available at https://www.gov.ca.gov/wp-content/uploads/2022/07/07.22.2022-Governors-Letter-to-CARB.pdf?emrc=1054d6. 3 LCFS Pathway Certified Carbon Intensities, Cal. Air Res. Bd, https://ww2.arb.ca.gov/resources/documents/lcfs-pathway-certified-carbon-intensities (last visited Oct. 20, 2022). 4 See Petition for Reconsideration of the Denial of the Petition for Rulemaking to Exclude All Fuels Derived from Biomethane from Dairy and Swine Manure from the Low Carbon Fuel Standard Program. Dated March 2022. Available at https://ww2.arb.ca.gov/sites/default/files/2022-04/2022-03-28%20-%20Petition%20for%20Reconsideration%20%2 8TOC%20Updated%29.pdf. |
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Date and Time Comment Was Submitted: 2022-10-27 13:56:29 |
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