What’s Up Docket? A Preview of Potential LCFS Amendments 

July 22, 2022 By , ,

Link to article: https://stillwaterassociates.com/whats-up-docket-a-preview-of-potential-lcfs-amendments/

By Adam Schubert 

CARB has been indicating for some time that the next round of revisions to the LCFS would come after the AB32 Scoping Plan was completed. With that in mind, CARB surprised many observers by holding an “informal workshop” on potential changes to the LCFS on July 7th. This session had about 700 attendees. The CARB staff presentation, a recording of the session, and a link for submitting comments can be found on CARB’s LCFS Meetings and Workshops webpage. The deadline for submitting comments is August 8th. 

In this article, we offer an abbreviated summary of what was covered in the July 7th informal workshop. For Stillwater’s full coverage of the LCFS program including this amendment process, subscribe to our LCFS Newsletter. 

Process – CARB indicated that there would be additional informal workshops held on potential LCFS amendments between now and when the Scoping Plan is finalized. 

Goals – CARB sees a more stringent LCFS as both desirable and feasible. As such, CARB staff are currently considering an increase in the required CI reduction in 2030 from the current 20% to 25% or 30%. Staff is also seeking input on how far past 2030 they should schedule CI reductions; it seems likely that CARB will ultimately extend the schedule at least out to 2035 and potentially to 2040. 

Other Issues – The staff presentation touched on several other concerns which they may look to address in the coming amendment package. Each of these possibilities may be explored in more depth in future workshops. 

  1. Phase out of support for mature technologies  
  2. Adding infrastructure credits for hydrogen refueling infrastructure and DC fast charging infrastructure for medium- and heavy-duty vehicles 
  3. Inclusion of fossil jet fuel used in intrastate flights as a deficit generator 
  4. Addition to the LCFS of novel low-carbon fuels such as dimethylether, methanol, and ammonia 
  5. Adding currently exempt uses such as rail, agricultural equipment, and marine harbor craft to the program 
  6. Considering whether current indirect land use change provisions are sufficiently protective to avoid disruptions of fuel markets or whether explicit caps on certain crop-based biofuels may be needed.  
  7. Supporting transport electrification in low-income and disadvantaged communities and rural areas 

Feedback – Most of the workshop time was spent receiving feedback from attendees. Some of the key topics which drew comments were: 

  1. Concern over the loss of renewable natural gas markets as natural gas vehicles are replaced by electric vehicles 
  2. Industry disagreement with CARB concerning whether electric forklifts are a mature technology and will continue to grow without LCFS support 
  3. The need for the LCFS Reporting Tool to be modernized 
  4. Expediting the pathway approval process and adding retroactive true-up 
  5. Methane reduction credits for dairy and livestock digesters  
  6. Exploring whether the LCFS can be used to incentivize low-carbon agriculture 
  7. Requests for the LCFS program to support synthetic fuels produced using Direct Air Capture 
  8. Requests that CARB work with the Oregon Department of Environmental Quality (DEQ) and Washington Department of Ecology (DOE) to harmonize and coordinate the states’ LCFS-style programs to the extent possible 

Questions on how potential LCFS changes may impact your business? We follow these issues closely and are available to review and analyze for your specific needs. Contact us! 

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