CARB proposal would strengthen near-term LCFS targets, cap the use of soy and canola feedstock
15/08/2024 (Biodiesel Magazine) - The California Air Resources Board on Aug. 12 published a notice outlining modifications to its proposed Low Carbon Fuel Standard amendments, including those related annual carbon intensity (CI) targets, biomass-based diesel feedstocks, and sustainable aviation fuel (SAF).
While proposed LCFS modifications issued last year would have added fossil jet fuel to the list of transportation fuels that are subject to the requirements of California’s LCFS, the modified language released on Aug. 12 proposes to eliminate that proposed requirement. The notice explains that CARB staff initially proposed to eliminate the currently LCFS exemption for fossil jet as to intrastate fossil jet fuel, but that public comments noted that proposal did not guarantee that airlines would procure and use alternative jet fuel as a compliance response. Rather, aviation fuel suppliers that would have generated deficits under the proposal could have simply acquired credits to meet their compliance obligations. “Staff remains committed to finding effective ways to reduce emissions from the aviation sector through the production and use of cleaner aviation fuels and other low-carbon alternatives to fossil jet fuel,” the agency wrote in the notice.
The proposed changes would also place a limit on the use of soybean oil and canola oil in biomass-based diesel production. Specifically, CARB is proposing to provide credits for biomass-based diesel produced from virgin soybean and canola oil for up to 20% of annual biomass-based diesel reported on a company-wide basis. Under the proposal, biomass-based diesel from virgin soybean and canola oil in excess of 20% would be assessed the CI of the applicable diesel pool benchmark for that year, or the certified CI of the applicable fuel pathway, whichever is higher. For companies that already have a certified fuel pathway prior to the effective date of the amendments and for which the percentage of biomass-based diesel produced from virgin soybean oil or canola oil was greater than 20% of combined reporting biodiesel and renewable diesel quantities for that company’s 2023 LCFS reporting, the provision would take effect Jan. 1, 2028, to provide time to adjust feedstock supply contracts as needed. All other companies would be subject to the requirement upon the effective date of the amended regulation.
In addition, the proposed modifications include changes to annual CI benchmarks. CARB is proposing to modify the near-term increase stringency to a 9% CI reduction in 2025, compared to the 5% year-to-year increase included in the initial amendments as proposed last year. CARB cited the continued growth in low-carbon fuels and stakeholder comments as the reason for the proposed change. The proposal also adjusts the compliance targets between 2025 and 2030 to smooth the curve between the more ambitious proposed target for 2025 and the originally proposed 30% reduction in 2030, which the agency has proposed to maintain.
For SAF, the proposal would add alcohol-to-hydrocarbons to CARB’s list of drop-in fuels in order to clarify that drop-in fuels include hydrocarbon fuels derived from alcohol. This includes SAF. “An alcohol to hydrocarbon pathway such as converting starch and cellulosic ethanol to jet fuel is one potential method of producing SAF,” CARB wrote in the notice.
CARB originally issued proposed amendments to update its LCFS program in late 2023, with a public comment period that was open until Feb. 20, 2024. A public hearing on the proposed amendments was originally scheduled to be held in March 2024, but was later delayed and is now scheduled for Nov. 8, 2024. The notice released on Aug. 12 includes a wide variety of updates to the originally proposed LCFS amendments that are subject to a 15-day public comment period, which will close Aug. 27. CARB could vote to implement the proposed amendments during the Nov. 8 hearing, with the proposed LCFS program changes in place as soon as early next year.