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

Mercy For Animals is a nonprofit organization dedicated to
constructing a just and sustainable food system, with approximately
24,000 supporters in California. We are writing to express concern
about the current state of California's Low Carbon Fuel Standard
(LCFS) and to implore you to take immediate action to address the
environmental injustices 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.

I urge you to 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. 

Mercy For Animals implores you to 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.

Sincerely,
Mercy For Animals

Alex Cerussi
Senior State Policy Manager
alexc@mercyforanimals.org
631.479.9005