In response to the release of the “15-Day Changes” to the Low Carbon Fuel Standard (LCFS) Proposed Amendments, the California Renewable Transportation Alliance (CRTA) offered comments that express general support for the California Air Resources Board’s (CARB) efforts to preserve and enhance the program’s stringency. However, CRTA also raised concerns about additional proposed limitations on dairy biomethane production and deliverability.

“In general, we think the 15-Day Changes continues to move the program in the right direction [and] … appreciate the thoughtful work staff have done thus far to ensure the correct market signals are sent to incentivize continued investment in low-carbon fuel production,” said CRTA President Nicole Rice. CRTA was particularly pleased with CARB staff’s decision to adopt the more ambitious 9 percent carbon intensity (CI) target, up from the initial 5 percent proposed during their Spring 2024 workshop.

However, CRTA highlight several concerns with the newly proposed language in their comment letter, including:

1. Reducing the Avoided Methane Crediting period from three consecutive 10-year crediting periods to two for projects breaking ground before January 1, 2030.
2. Continuing the “4-to-1” penalty for verified carbon intensity exceedance and extending it to the temporary pathway period.
3. Proposing a condition for early industry reporting of direct flow into the pipeline, which may prove unreliable and lead to confusion.

CRTA emphasized that any changes to dairy biomethane production under the LCFS should be thoughtfully evaluated to prevent increasing uncertainty for investors and to avoid negatively impacting the nationwide adoption of LCFS-type programs. This approach is crucial for maintaining California’s leadership in methane abatement and transportation fuel decarbonization.