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Dear Governor Newsom and Members of the California Air Resources
Board (CARB),
 I have concerns regarding California's Low Carbon Fuel Standard
(LCFS) and to implore you to take immediate action to address the
environmental injustices embedded in the program.

LCFS  has become the nation's largest and most lucrative pollution
trading scheme for factory farm biogas, perpetuating harmful
practices rather than serving its environmental objectives. 
It is driving the construction of more factory farms and factory
farm biogas projects in states far from California, causing severe
harm to air, water, public health, rural economies, and overall
quality of life. Incentives for more factory farms is not a
solution for combatting climate pollution by factory farms. 

I urge you to consider and prioritize the following reforms to the
LCFS:

Eliminate "avoided methane crediting" in 2024.
Address inaccuracies in the Life Cycle Assessment that ignore
associated up and downstream greenhouse gas emissions from factory
farm gas production.
Remove the 10-year "grace period" for factory farm gas producers.
Stop double counting by allowing factory farm gas projects paid for
and claimed by other programs to sell LCFS credits as well.