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Dear Dr. Laskowski,

On behalf of Loci Controls, Inc. ("Loci"), I am writing to
recommend that due to the urgent necessity of achieving short-lived
climate pollutant ("SLCP") emission reductions, the California Air
Resources Board ("CARB") should recognize a new methodology to
reduce methane emissions from large landfills within CARB's life
cycle analysis ("LCA") modeling for the Low Carbon Fuel Standard
program ("LCFS").  The specific methodology recommended here has
been fully approved by the American Carbon Registry ("ACR").  It is
referenced as the "Methodology for the Quantification Monitoring,
Reporting and Verification of Greenhouse Gas Emission Reductions
and Removals from Landfill Gas Destruction and Beneficial Use
Projects, version 2.0."  (hereafter the "ACR LFG Methodology").  
CARB's direct integration of the ACR LFG Methodology into the LCFS,
or CARB's development of an analogue in the LCFS to the ACR LFG
Methodology will spur the use of innovative SLCP technologies that
can be broadly implemented and thereby provide substantial
additional reductions of SLCP emissions. Thus this recommended
integration is fully aligned with CARB's priorities, and is
replicable at multiple landfills across California and the United
States.

The complete comment with the ACR methodology and data is attached.
 Please contact me for any questions or follow-up.

Best Regards,

Graham Noyes
Noyes Law Corporation for Loci Controls, Inc.
fuelandcarbonlaw.com