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