Comment Log Display

Dear Governor Newsom and Members of the California Air Resources
Board (CARB),

My family and I have strong concerns about the current state of
California's Low Carbon Fuel Standard (LCFS) and urge you to take
immediate action to address the more degradation of the 
environment that are embedded in the program.

Originally intended as a tool to combat climate pollution in the
transportation sector, the LCFS has been manipulated by powerful
corporations, particularly Big Ag and Big Oil. It has become the
nation's largest and most lucrative pollution trading scheme for
factory farm biogas, perpetuating harmful practices rather than
serving its environmental objectives. It is driving the
construction of more factory farms and factory farm biogas projects
in states far from California, causing severe harm to air, water,
public health, rural economies, and overall quality of life.

The current flaws in the LCFS, such as "avoided methane crediting"
and inaccurate life cycle assessments, not only enable pollution
but disproportionately harm low-income communities and communities
of color. Factory farms, predominantly situated in these
marginalized areas, inflict severe damage on air, water, public
health, rural economies, and overall quality of life.

Please consider and prioritize the following reforms to the LCFS:

1.	Eliminate "avoided methane crediting" in 2024.
2.	Address inaccuracies in the Life Cycle Assessment that ignore
associated up and downstream greenhouse gas emissions from factory
farm gas production.
3.	Remove the 10-year "grace period" for factory farm gas
producers.
4.	Stop double counting by allowing factory farm gas projects paid
for and claimed by other programs to sell LCFS credits as well.

CARB holds a pivotal opportunity this year to adopt new rules that
align the LCFS with California's environmental justice commitments.
Environmental justice, zero emission, and climate advocates have
presented a clear alternative to the current policies that heap
lavish rewards on the biggest polluters through the Comprehensive
EJ Scenario. CARB should adopt those recommendations to stop moving
California climate policy in the wrong direction.

Please lead the charge in demanding a future free from the clutches
of Big Oil and Big Ag. Prioritize the well-being of Californians
over corporate profits.  In this way, we can reform the LCFS to
protect communities most affected by its current flaws. 

Your decisive action in this serious matter would demonstrate a
commitment to bold climate action rooted in justice.  

Thank you. 
Sincerely, 
Pamela Gross & family