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Dear CARB Staff, 

Thank you for the opportunity to comment on the proposed Tier 1
dairy and swine manure (DSM) Calculator. 
We have taken in interest in Low Carbon Fuel Standard (LCFS)
programs throughout the United States and appreciate the
opportunity to provide feedback on California's LCFS regulation. 
CARB's exclusion of N2O emissions in the proposed DSM calculator
represents a missed opportunity to leverage emissions reductions in
the livestock sectors.
By allowing for avoided N2O and methane emissions from poultry
farming, CARB can create incentives for emissions reductions in
this important livestock category.
Including default co-product credits for the benefits of displaced
fertilizer represents an additional opportunity to reduce
agricultural emissions.
We appreciate the opportunity to provide feedback and contribute to
the ongoing efforts to address agricultural emissions and mitigate
environmental challenges. We believe that by including N2O
emissions from manure management and allowing avoided emissions
from poultry farming, CARB can unlock substantial potential for
reducing greenhouse gas emissions in the agricultural sector. Thank
you for your time and consideration in advancing sustainable
solutions and working towards a greener future for California.

Original File Name: LCA_tier_1_DSM_comment letter_final.pdf

Date and Time Comment Was Submitted: 2023-07-12 12:19:52