08.27.24 | Comments to CARB in response to the August 12, 2024 release of the “15-Day Changes to the Proposed Amendments to the Low Carbon Fuel Standard” (15-Day Changes).
Overall, the California Renewable Transportation Alliance (CRTA) believes that the 15-Day Changes continue to advance the LCFS program in a positive direction. We appreciate the thoughtful work staff has done thus far to ensure the correct market signals are sent to incentivize ongoing investment in low-carbon fuel production, particularly related to dairy biomethane.
We support several of the proposed changes, such as the increase in the program’s near-term carbon intensity stringency and the inclusion of the “True Up” provision. However, we also have concerns regarding some of the new language related to dairy biomethane deliverability and production.
The Low Carbon Fuel Standard (LCFS) is internationally recognized as an effective mechanism for decarbonizing transportation fuel, reducing California’s dependence on fossil fuel, and incentivizing the reduction of methane emissions from dairy operations. CRTA believe it is crucial that any modifications to this program are carefully designed and considered to maintain California’s leadership in this area. Additionally, changes to dairy biomethane production under the LCFS should be thoughtfully evaluated to prevent increased uncertainty for investors and to avoid negatively impacting the nationwide adoption of LCFS-type programs.