RECAP: CARB April 10 LCFS Workshop

The California Air Resources Board (CARB) held another workshop on the Low Carbon Fuel Standard (LCFS) on April 10th. From the slide deck you can see that the main topics discussed included new options for greater near-term carbon intensity (CI) stringency and the treatment of crop-based and renewable diesel.  CARB staff also spent some time recapping on the rigor and data used to inform the current draft amendments to further reiterate that their position is based in relevant science. Staff did not discuss anything that would suggest a deviation from their current treatment of dairy biogas in the draft langauge.

Relating to CI stringency, staff introduced a more aggressive “step-down” provision that would reduce the CI target between 7 and 9 percent in 2025 versus the originally proposed one-time “step-down” of 5 percent in the amendment package. This new increase would still get us to a 30 percent CI reduction by 2030 and a 90 percent CI reduction by 2045, although CRTA believes an even deeper pre-2030 target (closer to 40 percent) is achievable (ICF study).

Additionally, staff also considered an alternative combined 5 percent “step-down” with two Auto-Acceleration triggers (which would automatically trigger a set increase in the CI reduction target if certain specified market conditions). This alternative would result in a 39 percent CI reduction by 2030 but a 90 percent CI reduction two years early (in 2043).

CRTA supports increased near-term (pre-2030) stringency to balance and stabilize the credit market, which has experienced historic lows in recent years. However, we are still evaluating the potential benefits and impacts of these two options.

The Environmental Justice Advisory Committee (EJAC) was also given 30 minutes at the top of the agenda to reiterate their proposed amendments to the LCFS, including the elimination of incentives for dairy methane capture and use, which is fundamental to California meeting its methane reduction mandates and climate goals.

It was, however, encouraging to hear CARB staff speak to their position on the need for methane capture and the use of biomethane to displace fossil natural gas use in hard-to-decarbonize sectors. Staff punctuated this point by stating it would be better for California to use cleaner combustion fuels (like those derived from dairy methane capture) than to rely on fossil diesel to fuel the combustion trucks that will still remain on the road during the transition.

For the next 30 days, staff is collecting questions and feedback on the proposals presented during the workshop. The deadline for submissions is May 10, 2024 and can be provided via this form. CARB staff plans to release a 15-day amendment package sometime this summer for comment with a possible Board vote on a final proposal to occur as early as this Fall.