This week was the final deadline to provide comments to the California Air Resources Board regarding proposed modifications to the state’s Low Carbon Fuel Standard.

The Renewable Fuels Association filed comments on the proposal Monday.

In its comments and an attached analysis, RFA said empirical data clearly undermine CARB’s rationale for including the new sustainability requirements for grain-based ethanol. CARB alleges the requirements are necessary to provide “guard rails” against “rapid expansion of biofuel production and biofuel feedstock demand…that could result in adverse land use change.” But as RFA pointed out, the number of corn acres needed to meet California ethanol demand has decreased by more than 700,000 acres—or 20 percent—since the LCFS program began in 2011. “This empirical data clearly invalidate CARB’s rationale for implementing its additional sustainability provisions,” writes RFA Chief Economist Scott Richman.

Additionally, RFA encourages California to continue moving toward the approval of E15 since it is the only state that does not currently approve the use of E15.

On November 8, 2024, the California Air Resources Board approved amendments to the LCFS regulation to maintain momentum for global, national, and local private sector investment towards increasing cleaner fuel and transportation options for consumers, accelerating the deployment of zero-emission infrastructure and clean fuel production to support clean vehicle regulations, and keeping the state on track to meet statutorily mandated air quality and climate targets.