Submission Number: 676
Submission ID: 9726
Submission UUID: e62d6f38-d4e6-4c4b-b0ac-da420421f130

Created: Fri, 04/26/2024 - 12:24
Completed: Fri, 04/26/2024 - 12:25
Changed: Mon, 04/29/2024 - 08:38

Remote IP address: 75.231.106.8
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes


Submitted Comment
Ben Lilliston
Institute for Agriculture and Trade Policy
April 10 LCFS workshop

The Institute for Agriculture and Trade Policy (IATP) welcomes the opportunity to comment on the California Air Resources Board (CARB) April 10 workshop on the state’s Low Carbon Fuel Standard (LCFS). IATP is a 38-year-old, non-profit organization with headquarters in Minnesota that works nationally and internationally for fair and sustainable food and trade systems.

IATP submitted a comment (see attached) to CARB on February 15, 2024 expressing our concerns that California’s LCFS has contributed to the further expansion of the CAFO system in Midwest states, such as Minnesota and Wisconsin, through its skewed emissions intensity scoring and associated credits for large-scale Concentrated Animal Feeding Operation (CAFO)-derived biogas. We do not believe biogas projects that subsidize Midwest CAFOs are consistent with California’s LCFS intention and purpose: to reduce California’s GHGs through its transportation sector by requiring cleaner fuels. Of particular concern are the credits LCFS provides to large dairy and hog operations that are closely tied to water and air pollution and the loss of independent family farms in Midwest rural communities. Unfortunately, there is emerging evidence that the LCFS is incentivizing large CAFOs producing biogas to get even larger, further exacerbating their harm.

We are disappointed that the April 10 workshop did not adequately consider the impact and harm of the LCFS on rural communities outside of California. Most biogas projects in Midwest states would not be economically viable without extensive public resources. Accessing credits under the LCFS is considered critical for CAFO biogas project developers.

If CARB is going to allow the LCFS to grant credits to operations outside of California, it must fully assess the policy’s role in directly subsidizing large CAFOs in other states. It is essential that CARB consider the impact the LCFS policy is having on all rural communities – those in California and outside California.

We urge CARB to review IATP’s previous comment and those coming from states outside of California to aid the board in its evaluation of the existing LCFS in order to make necessary reforms.