In comments filed with the California Air Resources Board today, the Renewable Fuels Association stressed that the next iteration of the state’s Low Carbon Fuel Standard must be technology-neutral and allow low-carbon renewable fuels to compete fairly as California endeavors to achieve carbon neutrality by 2045.
RFA submitted the comments in response to a July 7 CARB workshop in which the agency laid out potential modifications to the LCFS and discussed options for the program’s design after 2030. Kelly Davis, RFA’s Vice President for Technical and Regulatory Affairs, urged CARB to ensure that the LCFS maintains its fuel-neutral focus and refrain from picking technology winners and losers.
“The hallmark of success of the LCFS is its market-based, technology-neutral approach that is driven by the carbon intensity scores of all fuels whether generating credits or deficits,” Davis wrote. “The RFA supports California’s goal of carbon neutrality by 2045. This is an aggressive, but achievable goal that will require a broad portfolio of low- and zero-carbon fuel solutions. The LCFS is a centerpiece policy in California’s decarbonization efforts and modifying and extending the LCFS regulation beyond 2030 is necessary to achieve carbon neutrality.”
RFA’s comments also stated that any sort of cap on crop-based biofuels—a concept that was discussed at the July workshop—would undermine the technology-neutral design of the LCFS and chill investments in low-carbon technologies. “Capping crop-based biofuel production would be the wrong market signal for an industry that continues to grow and innovate in meeting food, feed, fiber, and fuel markets,” according to the comments.
Davis added that if the intent of the “cap” proposed by some stakeholders is to “take credit generation pressure” off lipid-based biofuels like renewable diesel, the easiest and fastest way to do that would be to approve the use of E15. CARB recently posted key research supported by RFA, showing how E15 can reduce automotive emissions in the state.
The comments also stress the need for CARB to revise its indirect land use change (ILUC) emissions penalty for corn ethanol based on newer studies, better data and improved modeling methodologies.
In addition, RFA stressed that higher ethanol blends are an important tool for facilitating more stringent goals for carbon reduction. Higher blends of low-carbon ethanol represent the “nearest term and most affordable path” for immediate reductions of GHG emissions from the light-duty fleet, Davis wrote. The comments also encouraged CARB to take other complementary actions that would help facilitate the broader use of low-carbon ethanol blends in the state.
The comments included as an appendix a presentation, “Thinking Clearly About Agricultural Land Use, Productivity Gains, and the Impact of Ethanol Expansion,” that showed how U.S. cropland is decreasing and increased commodity demands have been met through remarkable increases in productivity.