The California Air Resources Board’s Low Carbon Fuel Standard (LCFS) seeks to incentivize the production and sale of alternative, lower-emissions transportation fuels to displace conventional fossil fuels. But there are some well-documented questions about the program’s incentives for industrial dairy operations. This report analyzes several commonly raised issues regarding California’s dairy digester policy. The report comes as the California Legislature declined to move on SB 709, a bill introduced last year to reform the role of dairy biogas in the LCFS.