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Thank you for the opportunity to provide comments on the November
9th workshop on potential changes to the Low Carbon Fuel Standard
program. 

Life Cycle Associates (LCA) has worked with several stakeholders on
projects at various stages of digester development on existing
dairy farms. At the workshop on November 9th, the Animal Legal
Defense Fund objected to the current methane avoidance crediting on
the basis that the current LCFS regulation incentivizes the
expansion of dairies and increases in herd size. However, this
contradicts our understanding of what would be considered
acceptable within the program.

LCA advises clients against planning significant changes in herd
sizes. From our understanding, expanding a dairy or starting a new
dairy for the purpose of generating more LCFS credits is not in
alignment with the goals of the LCFS program, and would not pass
verification. 

We respectfully request that CARB provide guidance on what changes
in herd sizes would be considered acceptable within the LCFS
program

Thank you for considering our comments. We look forward to
continuing to work with you and other stakeholders to further the
goals of the LCFS program.

Original File Name:

Date and Time Comment Was Submitted: 2022-12-21 19:47:38