Comment Log Display

	Iowa Citizens for Community Improvement urges the Air Resources
Board to grant the recent Petition for Rulemaking to Exclude All
Fuels Derived from Biomethane from Dairy and Swine Manure and amend
the LCFS accordingly. Iowa CCI is a statewide organization with a
communication base of 15,000 everyday Iowans working to win social,
environmental, economic and racial justice. We want to reform our
food and farm systems to work for farmers, workers, eaters, and the
planet. Amending the LCFS to exclude fuels from methane captured
from factory farms is an important step toward this critical
reform. 
	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.
	We 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.

	We are extremely concerned that the LCFS, which the ARB adopted
with the intention to reduce greenhouse gases from California
transportation fuels, will perversely incentivize more and larger
hog and dairy confinements in Iowa. Over the last several decades,
the number of permitted livestock facilities has increased
dramatically from 722 (93% hog) in 2001 to over 10,000 in 2017. But
recently, the Iowa legislature exempted confinement operations from
a permitting requirement for operations greater than 8,500 animal
units if an operation installs an anaerobic digester system to
capture biogas.  The Cedar Rapids Gazette reports that nine Iowa
dairies have applied for permits for anaerobic digesters, seven are
expanding herd sizes as part of the process, and two are utilizing
the exemption because their herd sizes will exceed 8,500 animal
units. 
	The LCFS program has drawn significant interest from factory farms
in California and other states with many factory farms taking
advantage of lucrative LCFS credits. We do not want to see your
transportation fuel policy entrench and enrich corporations like
Iowa Select, Smithfield, Tyson, JBS, and Prestage Farms at the
expense of our communities, land, air, and water. Even worse, we
are extremely concerned that the value of LCFS credits for
biomethane from hog and dairy waste will incentivize expansions and
even more confinement operations. Right now, Iowa agricultural
runoff is contributing approximately 30 percent of the nitrogen
load feeding the Gulf Dead Zone off the coast of Louisiana, and
that amount has been increasing.  And this runoff is polluting our
drinking water as well.  Turning Iowa factory farms into sources of
credits to offset California transportation fuel emissions will
inevitably generate more incentives to increase more manure which
will further degrade our communities and water quality.
	We hope that you recognize the consequences that your policy
choice has inflicted and will inflict. We urge you to amend the
LCFS to stop utilizing out-of-state factory farms as a source of
offsets for your pollution trading scheme. We also ask that, at a
minimum, you amend the LCFS to correct the over-valuation of
manure-based credits to include all climate pollution associated
with the factory farm system and ensure that credits from
non-additional reductions do not continue.
	Instead of pitting our states and residents against each other, we
should be working together to implement real solutions that protect
our communities, our farmers, our workers, and our planet. Thank
you for considering these comments.