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Eliminate avoided methane crediting for fuel derived from livestock
manure.

- Oppose Proposed LCFS Amendment Loophole to Allow Petroleum
Projects with Carbon Capture & Storage Past the 2040 Phase-out.

I recommend a number of measures, to wit: 
Conduct and incorporate a full life cycle assessment of all air
pollution and greenhouse gas (GHG) emissions for all pathways, and
their implications for environmental justice communities.

- Create ZEV multipliers to boost electric school bus and electric
public transit bus and rail system deployments.

- Eliminate credit generation from factory farm gas projects that
would have happened anyway due to other programs or investments.

- Include intrastate jet fuel as a deficit generator and include
California's share of the fuel used in interstate and international
flights.

- Allow credits for zero-emission transportation fuels used for
ocean-going vessels, and simplifying the process for credits for
shore power installations serving electrified harbor crafts and for
dispensing green hydrogen.