CRTA Comments on Proposed LCFS Amendments

The California Renewable Transportation Alliance (CRTA) recently submitted comments to the California Air Resources Board (CARB) on staff’s proposed amendments to the Low Carbon Fuel Standard (LCFS) program.

CRTA strongly supports staff’s recommendations to continue the application of Avoided Methane Accounting and the use of “Book & Claim” deliverability for renewable natural gas (RNG) projects developed on or before December 31, 2029. This will “restore project planning predictability for investors thereby avoiding stranded assets and incentivizing continued low carbon fuel production.” Maintaining strong RNG pathways today ensures future availability of this versatile fuel for use in other hard-to-decarbonize sectors, as envisioned in CARB’s 2022 Scoping Plan for Achieving Carbon Neutrality. The Alliance is also strongly in favor of providing additional time under these provisions for RNG-supported hydrogen pathways to incentivize continued production and capitalize on early funding for infrastructure and production. 

CRTA also encouraged staff to be more bold in its carbon-intensity targets to correct the current decline in credit prices and stabilize the market. Credit prices continue to decline and most recently, have hit an all-time-low of $55.  Recent studies conclude that increased stringency is possible so a quick, decisive response is needed to correct the seriousness of the credit market situation.

Overall, Alliance Members believe that staff’s proposed modifications to the LCFS related to the treatment of biomethane strikes the “right balance” by enabling RNG to provide “significant emission reductions in the near-term while remaining a source of energy to power zero-emission platforms” in the future. Embracing a balanced approach to transportation decarbonization is a hallmark of our organization and we applaud its application in this context.

Our full comment letter can bee found here.