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I support the EJAC's resolution and hope that you give it the
weight it deserves.  My conclusion after listening to SB 32 Scoping
Update workshops was that CARB solicits EJAC input and then ignores
it. That's still structural racism in liberal clothing.  This time
I hope you do better. 

Extremely and undeservedly generous credits incentivize the
proliferation and growth of confined feeding operations which have
numerous proven impacts to air, water, and surrounding
environmental justice communities. They also support the
overproduction of concentrated dairy products which contribute to
rates of obesity, heart disease and cancer; and air pollution from
biogas combustion, all of which fall more heavily on BIPOC
communities.   

Full life cycle analyses are needed before the mitigation value of
bio-methane can be assessed.  These LCAs must take into account
methane leaks from digesters, distribution chains, and digestate; 
methane from enteric fermentation, and emissions from the
production of rations for confined feeding.   

There also needs to be re-evaluation of the impacts of land use
change from growing biofuel feedstock  on the climate and on
indigenous people, as demand for plant oils has increased
dramatically and will continue to grow. 

Thanks for the chance to comment.