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The Center for Biological Diversity appreciates the opportunity to
comment on CARB's proposed changes to the Low Carbon Fuel Standard
(LCFS). We offer several concerns and suggestions. 

We have attached a PDF with our full comment. 

In summary, our concerns: 
First, now that California has banned use of carbon dioxide (CO2)
from carbon capture and storage (CCS) for enhanced oil recovery
(EOR) within the state, CARB must remove CCS-related EOR from the
LCFS. At present, CARB continues to incentivize EOR out-of-state
and assume use of this harmful technology in its modeling.
Second, CARB's carbon intensity calculations for fuels made using
CCS, such as ethanol with CCS and blue hydrogen, fail to reflect
real-world CO2 capture efficiencies or account for CO2 and methane
emissions across the CCS lifecycle. As a result, CARB significantly
underestimates the carbon intensities of fuels made using CCS, and
these methodological errors must be corrected. 
Third, CARB's CA-GREET model currently underestimates the carbon
intensity of fuels made with fossil gas and biogas, such as CNG
fuels, factory farm gas, and hydrogen, because it relies on
assumptions for methane leakage that dramatically underestimate
leakage rates and are inconsistent with the best-available
science.
Finally, CARB must consider an alternative with aggressive targets
in carbon intensity reductions and rapid phase-down of fossil fuels
that incentivizes truly renewable fuels that minimize impacts,
rather than alternatives that emphasize technologies like CCS. 

Please note that we have attached references cited in this letter
in a .zip file titled, "Ctr. Biol Div Refs LCFS 12.2.22," for
CARB's consideration and for inclusion in the public record.  

Original File Name: 22.12.2 LCFS Comment - Ctr Biol Diversity .pdf

Date and Time Comment Was Submitted: 2022-12-02 08:46:31