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

I am writing to express my deep concern about the current state of
California's Low Carbon Fuel Standard and to implore you to take
immediate action to address the environmental injustices embedded
in the program.

Including factory farm gas in the LCFS:
1. Incentivizes more corporate factory farms, harming family
farmers, rural communities, and our environment. 
2. Creates additional overproduction of commodities, pork and milk,
increasing supply and further pushing down market prices paid to
independent family farms.
3. Pays foreign multinational meatpackers, like Chinese-owned
Smithfield and Brazilian-owned JBS, for their pollution.
4. Commoditizes methane production, which would fuel more methane
producing practices.

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 our 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. By prioritizing the well-being of
Californians over corporate profits, we can reform the LCFS to
protect communities most affected by its current flaws. Your
decisive action in this critical matter would demonstrate a
commitment to bold climate action rooted in justice. Please stop
exporting your bad policy to our front doors.

Thank you.