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Good morning Chair and Members.

My name is Akashdeep Singh and I am speaking on behalf of Union of
Concerned Scientists. We have been a long time supporter of the
LCFS and have been involved in its implementation for more than 15
years. The LCFS provides vital support for transportation
electrification which will be key to achieving CARB's other
critical regulations.

However, we are here today in solidarity with many of the
environmental and environmental justice organizations you have
heard from today to urge CARB to modernize the LCFS to ensure it
equitably meets the needs of Californians and supports the
attainment of air quality standards.

First, the drop in credit prices that precipitated this process
came from a glut of renewable diesel credits. CARB must place a
hard cap on the share of compliance from lipid-based biofuels to
the LCFS in balance. The current proposal to simply increase
stringency and would result in worse economic consequences with
fewer environmental benefits.

Further, avoided methane credits for dairies must be phased out
more quickly than staff is proposing. CARB should instead seek to
regulate methane emissions from dairy's as soon as they are legally
allowed to do so next year. 

California must continue steadfastly moving away from combustion in
the transportation sector. The LCFS can play a key role in this
transiton, but if there are not significant changes to the current
proposal, the LCFS would not live up to that promise and could even
be counterproductive.

Thank you so much!