Submitted Comment Name Simona Vanecek Affiliation N/A Subject Subject: Public Comment on Tier 2 Pathway Application B078801 – Chevron Meadow Rock RNG LLC Message Subject: Public Comment on Tier 2 Pathway Application B078801 – Chevron Meadow Rock RNG LLC To the LCFS Pathway Processing Team: Thank you for the opportunity to provide public comment on Application B078801, concerning the production of biogas from dairy manure at the Meadow Rock RNG facility and its transport for use as a transportation fuel in California. I respectfully request that CARB review the following points for accuracy, completeness, and alignment with LCFS regulatory requirements: 1. Methane Capture and Avoided Emissions Assumptions Dairy manure pathways rely heavily on assumptions about methane capture efficiency and avoided baseline emissions. Because real‑world manure management practices vary significantly, I encourage CARB to verify that the baseline scenario and project scenario are accurately represented and do not overstate avoided methane emissions. 2. Transport‑Related Emissions This pathway includes trucking biogas to a pipeline injection site and transporting it to California. All transport‑related emissions — including trucking, compression, and pipeline movement — should be fully accounted for, as they can materially affect the final carbon intensity score. 3. Feedstock Sourcing Transparency Dairy manure feedstock characteristics can vary based on herd size, manure handling, and digester operation. I encourage CARB to ensure that the feedstock sourcing information is complete, verifiable, and consistent with LCFS requirements, particularly regarding manure that may already be managed in ways that reduce methane emissions. 4. Avoiding Double‑Counting of Environmental Benefits Dairy digester projects may receive incentives from multiple programs. I recommend confirming that no avoided emissions or environmental benefits are being counted more than once across programs or regulatory frameworks. 5. Community and Environmental Justice Considerations Although Tier 2 pathways focus on carbon intensity, dairy manure projects can have localized impacts on surrounding communities. I encourage CARB to ensure that the project complies with all applicable environmental justice and air‑quality protections in the host region. Closing Thank you for your continued commitment to transparency, scientific rigor, and environmental integrity in the LCFS program. I appreciate your review of these comments. Respectfully submitted, Simona Vanecek Written with the assistance of Microsoft Copilot File Upload (i.e., Attachments): N/A N/A
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