Submission Number: 829
Submission ID: 11236
Submission UUID: 3af65774-cdee-47e8-9111-bfc2eae9c1b5

Created: Fri, 05/10/2024 - 12:42
Completed: Fri, 05/10/2024 - 12:43
Changed: Mon, 05/13/2024 - 09:01

Remote IP address: 140.186.77.26
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes
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Submitted Comment
Nancy Johnson
North Dakota Soybean Growers Association
Comments on April 10 Low Carbon Fuel Standard Workshop

The North Dakota Soybean Growers Association (NDSGA) appreciates the opportunity to provide comments in response to the April 10 Low Carbon Fuel Standard (LCFS) workshop. The NDSGA is an affiliate of the American Soybean Association (ASA) and welcomes the chance to engage with the California Air Resources Board (CARB) regarding its most recent workshop.
NDSGA represents North Dakota soybean farmers on domestic and international policy issues important to the soybean industry. U.S. soybean growers have long been committed to producing the world’s food, feed, fuel, and thousands of bioproducts in a sustainable and climate-smart way.
As CARB revises and refines provisions in the Initial Statement of Reasons (ISOR) package, NDSGA is pleased to expand ASA’s comments provided during the April 10 workshop. Of highest importance is ensuring that sustainability guardrails are workable for the soybean industry. Additionally, NDSGA requests that CARB update soybean land use change modeling that uses 20-year-old data and does not reflect current growing practices. Given the recent federal tax guidance released in April on sustainable aviation fuel, there are also additional opportunities to develop LCFS policies that complement work being done at the federal level rather than create duplicative frameworks that create additional burdens on the biofuels value chain.
Complete NDSGA letter is attached.