The California Air Resources Board (CARB) has released additional changes to their proposed Low Carbon Fuel Standard (LCFS) amendments. These new revisions (dubbed the 15-Day Changes) further modify the existing proposal released in December 2023 (45-Day Changes). Below is a list of key revisions identified in the notice:

• Biomethane book-and-claim. CARB staff proposes modifying the deliverability requirements for book-and-claim accounting for biomethane by adding a condition that pathways for bio-CNG, bio-LNG, and bio-L-CNG combustion in vehicles would need to demonstrate physical flow to California after December 31, 2037 if the Executive Officer approves a gas system map identifying interstate pipelines and their majority directional flow.
  
• Avoided methane crediting. CARB staff propose reducing the total number of crediting periods for avoided methane emissions crediting periods to two (rather than the three previously proposed) for projects breaking ground before January 1, 2030. Staff reason that this change “aligns more closely with the end-dates for avoided methane pathways that break ground after December 31, 2029, which was proposed in the Staff Report 3, while still providing an incentive to develop methane capture projects.”
  
• Carbon intensity reduction. CARB staff propose modifying the near-term increase in stringency to a 9% carbon intensity (CI) reduction in 2025. This represents a change from the 5% year-to-year increase included in the initial amendments proposal, but maintains the originally-proposed 30% reduction for 2030. This change in near-term stringency ambition was offered “in light of the continued growth in low-carbon fuels and in response to stakeholder feedback requesting an increase in stringency to bring deficits and credits into balance.”
  
• True-up and crediting periods. CARB staff propose expanding the credit true-up to include periods using temporary pathway CIs after annual verification. Staff believes that this proposed amendment will smooth out the impact from the avoided methane crediting modifications above and “will ensure sufficient return on investment for fuel pathways reporting using temporary fuel pathways during the pathway certification process.”

Public comment on these modifications is due by August 27, 2024. Click here for more details on the proposed changes and for comprehensive access to all the regulatory materials.