The Renewable Fuels Association (RFA) filed comments this week with the California Air Resources Board on the future of the state’s Low Carbon Fuel Standard, stressing that it must be technology-neutral and allow low-carbon renewable fuels to compete in the marketplace to achieve carbon neutrality by 2045.
RFA submitted the comments in response to a July 7 CARB workshop in which the agency laid out potential modifications to the LCFS and discussed options for the program’s design after 2030. Kelly Davis, RFA’s Vice President for Technical and Regulatory Affairs, urged CARB to ensure that the LCFS maintains its fuel-neutral focus and refrain from picking technology winners and losers.
“The hallmark of success of the LCFS is its market-based, technology-neutral approach that is driven by the carbon intensity scores of all fuels whether generating credits or deficits,” Davis wrote. “The RFA supports California’s goal of carbon neutrality by 2045. This is an aggressive, but achievable goal that will require a broad portfolio of low- and zero-carbon fuel solutions. The LCFS is a centerpiece policy in California’s decarbonization efforts and modifying and extending the LCFS regulation beyond 2030 is necessary to achieve carbon neutrality.”
RFA’s comments also stated that any sort of cap on crop-based biofuels—a concept that was discussed at the July workshop—would undermine the technology-neutral design of the LCFS and chill investments in low-carbon technologies. “Capping crop-based biofuel production would be the wrong market signal for an industry that continues to grow and innovate in meeting food, feed, fiber, and fuel markets,” according to the comments.