Last month, CARB held another workshop on proposed changes to the Low Carbon Fuel Standard (LCFS).  Now that the Scoping Plan has been approved, staff intends to move more quickly on implementing modifications to the Program.  More than 700 people participated in the webinar where slides and preliminary concept language were reviewed.  Staff is currently soliciting comments from that discussion through March 15, 2023.

While staff emphasized their intent not to phase out the use of renewable natural gas (RNG) under the Program, they nonetheless confirmed a declining role for RNG as a primary fuel source.  CRTA and others remain concerned about the proposed restricted use of RNG (or biomethane) as envisioned for the future of LCFS.

We appreciate CARB action to continue the inclusion of RNG as a credit-generating fuel under the LCFS but caution them against any efforts to reduce or restrict its production or supply in California.  LCFS is a primary driver for the effective and efficient capture and reuse of methane – the world’s second most abundant GHG and a potent Short-Lived Climate Pollutant (SLCP). Continuous methane emission diversion, regardless of location, should be encouraged.

Credits for avoided methane emissions will result in market certainty and stability that drives private investment for projects that would otherwise be cost-prohibitive for participants. Without these credits, the state’s ability to achieve the decarbonization goals and mandates contained in both the 2022 Scoping Plan Update and Senate Bill 1383 (Chapter 395, Statutes of 2016) will be threatened.

Additionally, we strongly discourage limiting RNG use in medium- and heavy-duty (MHD) vehicles. The best and highest use for RNG still remains in the heavy-duty (HD) transportation sector. With a majority of California MHD trucks still operating on higher-emitting diesel fuel, the most immediate way to decarbonize the transportation sector is to replace MHD diesel trucks with renewable fuels, and  the most readily available option today is RNG. Engines powered by RNG are certified by CARB as 90% cleaner than diesel and RNG is the only negative carbon intensity fuel under the LCFS, at -33.36 gCO2e/MJ for all of 2021.

Diverting RNG use away from transportation will result in continued and possibly increased exposure to toxic diesel pollution for the state’s most vulnerable populations adjacent to the transportation corridors. And, even though RNG can yield significant and beneficial emission reductions in other industry applications, the most effective, immediate use for RNG is in the “hard-to-electrify” HD transportation sector.

This use should be prioritized and any other industry uses should be secondary.