California Air Resources Board

Thank you to CARB for providing a forum for public comment. Thank you to Brightmark LNG for submitting your application.

As a CA resident who pays for LCFS costs passed on to the consumer, I find it hard to support any application that can't demonstrate deliverability to California. I realize non-deliverable fuel credits are to be phased out eventually, but I have to complain that they are allowed at all.

LCFS costs are passed along to the end consumer, per my understanding. That being said, every California resident is being asked to pay for/subsidize natural gas produced in New York, if my simple mind is comprehending this application correctly. My first thought is I must be misunderstanding something because this makes no sense. Why should I as a California resident be subsidizing a New York producer when the RNG they produce is across the country from California and not consumed here? I am happy to subsidize any California producers of RNG, as the methane offsets occur here in-state, and the beneficiaries of any such LCFS credits are California citizens who I interact with daily.

To be blunt, book-and-claim for out of state fuels is bulls**t. California LCFS is something I support for fuels consumed in state. Subsidizing non-California fuels that never even get close to being consumed in-state through paying higher prices for in-state fuels is a tax on Californians without the benefit of local greenhouse gas reduction. Book-and-claim for RNG is the most egregious of oversights in the CARB LCFS program, in my humble opinion. I will write negative comments for every such project henceforth.

Nothing against the New York producers of such RNG. More power to you. For a "book-and-claim" project to be valid, imo, it should be applied against a NATIONAL LCFS program and not a STATE program such as CARB's LCFS program. Once again, the cost of LCFS are passed on to California residents, not New York residents. Should New York RNG producers wish to be benefit from any LCFS-type programs than they should take this up with their state government, or the Federal government in order to obtain and LCFS program under those jurisdictions.

Sincerely,
Josh Kehoe