California Air Resources Board

On behalf of Loci Controls, Inc. (“Loci”), I am writing to provide comments relating to the issues raised at the Public Workshop on Potential Improvements to the Landfill Methane Regulation (“LMR”).  Specifically, this comment focuses on the benefits of the California Air Resources Board (“CARB”) developing a strategic plan to integrate advanced real-time landfill gas monitoring and collection systems (“Advanced LFG Control Systems”) into the LMR while also leveraging the economic benefits of the Low Carbon Fuel Standard program (“LCFS”) to speed industry adoption and begin capturing short-lived climate pollutant (“SLCP) reductions even before the future LMR’s effective date.  Loci recognizes CARB’s ground-breaking work in quantifying fugitive methane emissions, and in deploying policy strategies to maximize the capture and beneficial use of biogas which will displace CO2 emissions downstream of landfills.  We also appreciate that CARB recognizes that there are significant opportunities to reduce methane and other harmful gas emissions from the emission source itself, landfills.   We appreciate the opportunity to provide this comment.

The full comment is attached.  Please advise of any problems or questions relating to this filing.

Best Regards,

Graham Noyes 

Noyes Law Corporation for Loci Controls, Inc.

401 Spring Street, Suite 205

Nevada City, CA  95959

www.fuelandcarbonlaw.com 

(530)264-7157 Direct

(206)856-8784 Cell

graham@noyeslawcorp.com