In comments submitted to the California Air Resources Board on proposed amendments to that state’s Low Carbon Fuel Standard, the Renewable Fuels Association expressed concerns about a previously undiscussed sustainability certification program and the state’s continued delay in allowing sales of the lower-carbon E15 fuel blend.
“Imposing a third-party verification system for feedstock certification places an extreme audit burden on feedstock suppliers and biofuel producers without any clearly defined benefit,” wrote RFA Chief Economist Scott Richman, who noted that the proposal came from nowhere and with no stakeholder input. “The audit report summaries would need to be designed so that their publication does not result in the disclosure of sensitive or confidential business information.”
He added that the provision does not even define the general term “sustainability” and needs extensive stakeholder engagement and analysis before being considered for inclusion in any amendment to the LCFS program.
He added that the provision does not even define the general term “sustainability” and needs extensive stakeholder engagement and analysis before being considered for inclusion in any amendment to the LCFS program. Were such a program to be implemented, Richman wrote, it should only apply to imports and exclude domestic supplies.
Regarding E15, Richman wrote that California is now the only state that does not allow the fuel, and that RFA and others have been working to ensure CARB has all the information it needs to make an informed decision to allow the fuel. “E15 is the leading opportunity under the LCFS to immediately and significantly further reduce GHG emissions while at the same time reducing criteria pollutant emissions and consumer costs,” he wrote.
The RFA comments also addressed four other provisions in the proposed amendments:
- Allowing the auto acceleration mechanism to be triggered as early as 2026 and to apply to consecutive years would be more effective in supporting a robust LCFS.
- Indirect accounting for low-carbon-intensity hydrogen production through power purchase agreements should be extended to the production of all low- to zero-carbon biofuels.
- Providing credits to companies achieving a lower operational CI for a fuel pathway is reasonable, but the multiplier proposed for exceeding the pathway CI is disproportionate.
- The requirement that verification bodies/individual verifiers be rotated every six years should be revised.
