California Air Resources Board

The Honorable Liane M. Randolph, Chair
California Air Resources Board
P.O. Box 2815
Sacramento, California 95812

RE: California Farm Bureau’s Comments Relating to the Proposed Amendments to the Low Carbon Fuel Standard

Dear Chair Randolph,

We appreciate this opportunity to provide feedback on the items discussed at the April 10, 2024, LCFS workshop.
California Farm Bureau (CAFB) is an innovative, service-based organization dedicated to being the foremost advocate, protecting the future and quality of life for all California farmers and ranchers. CAFB protects California’s diverse farming and ranching legacy and enables the whole agriculture community to thrive. With over 29,000 members, CAFB is California's largest agricultural association.
California family farmers are community members and are committed to the health and wellbeing of their neighbors. Unlike other economic sectors, the products California’s farmers produce are used and needed by all Californians. We take great exception to much of the anti-farming, and anti-science rhetoric being offered up at the workshop by representatives of the AB 32 Environmental Justice Advisory Committee and some public comments which are clearly attacks on the agriculture community.

We support continued use of Avoided Methane Pathways
The current LCFS crediting regime for biomethane derived from animal manure is delivering the significant benefits it was designed to achieve. Specifically, the current LCFS crediting incentive for methane capture for transportation fuel use appears to be spurring the development of new digester projects. Since the 2018, LCFS amendments came into effect, the number of digesters has grown from around 20 to more than 100 operating today.
CAFB agrees that reducing methane is the quickest and best way to meet our emissions goals. Avoided methane capture is on track to meet our goals, and LCFS is one critical reason as to our success.
California’s digesters have tremendous potential for GHG reductions—targeting methane, a short-lived climate pollutant— and also can reduce other air emissions and improve air quality. Building and operating a manure digester is expensive and the financing of new projects, and continue operation of existing ones, may depend on the continued availability of CI credits in the LCFS program. It is crucial that we continue to send signals to the market regarding the stability and certainty of LCFS.
Manure digesters have the greatest potential to address two overlapping barriers to meeting California’s ambitious climate goals: How to reduce methane emissions and how to produce large amounts of RNG needed for zero-carbon transportation and achieving a zero-carbon electric grid. We understand that LCFS is a bridge fuel, and until better options are available, it is premature to reduce support for new and existing methane digesters.

Crop-Based Biofuels Sustainability Criteria
CAFB appreciates CARB’s recognition of the critical role that crop-based fuels play in meeting our climate goals. Based on a lack of evidence that the use of crops for fuel feedstocks has negatively impacted public health or food prices, we would argue that the need for a sustainability certification program is premature. However, if there is to be a certification program, we feel that the California Air Resources Board would be the most appropriate body to develop it, and that Farm Bureau and its members should participate in its development. Included in that endeavor should be a stakeholder process to adequately address the implications that might arise, and the effects that it would have on agriculture, and specifically the certifications for feedstocks that come from climate-smart agriculture.
Additionally, due to California’s existing, robust environmental, labor, and land use regulations, we would also argue that any crops or crop wastes produced in California, by California farmers should be automatically considered “sustainable” for the purposes of this program.
We appreciate the complexity of this rulemaking package and staff’s dedication to working with all stakeholders to ensure the best possible outcome. We look forward to continuing this conversation.

Sincerely,

Steven Fenaroli
Political Affairs Director, California Farm Bureau