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Comment #69 for Public Workshop to Discuss Potential Changes to the Low Carbon Fuel Standard
(lcfs-wkshp-nov22-ws) - 1st Workshop

First Name: Graham
Last Name: Noyes
Email Address: graham@noyeslawcorp.com
AffiliationNoyes Law Corporation
SubjectAutomated Landfill Control Technology Can Accelerate Methane Reductions
Comment
Dear Dr. Laskowski,

On behalf of Loci Controls, Inc. ("Loci"), I am writing to
recommend that due to the shortfall identified in the Final 2022
Scoping Plan regarding short-lived climate pollutant ("SLCP")
emission reductions, the California Air Resources Board ("CARB")
should provide recognition to automated landfill monitoring and
control technologies within the Low Carbon Fuel Standard program
("LCFS") to speed methane emissions from landfills.  Loci
recognizes CARB's ground-breaking work in quantifying fugitive
methane emissions, and in deploying policy strategies to maximize
the capture and upgrading of biogas so that it can be beneficially
used as renewable natural gas ("RNG") to displace fossil natural
gas.  We appreciate the opportunity to provide this Comment.

Loci's full comment on these issues is attached.   Please contact
me if there are any issues or questions relating to the comment.

Best Regards,

Graham

Graham Noyes
Noyes Law Corporation
401 Spring Street, Suite 205
Nevada City, CA  95959
www.fuelandcarbonlaw.com 
(530)264-7157 Direct
graham@noyeslawcorp.com 
Attachment www.arb.ca.gov/lists/com-attach/78-lcfs-wkshp-nov22-ws-Uj5SOwRmWWNXDlc0.pdf

Original File Name: Loci Controls CARB LCFS Comment 21 Dec 2022 Final.pdf

Date and Time Comment Was Submitted: 2022-12-21 10:17:26


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