CARB's Low Carbon Fuel Standards by the Numbers

The California Air Resources Board (CARB) hosted a workshop on April 10, to provide more detail on the loosely-defined ‘sustainability guardrails’ and present additional data and analysis related to its rulemaking proposal released in late December. One piece of the supplemental analysis was for me the most notable takeaway of the day. 

For context, there has been a well-orchestrated--and presumably well-funded--public influence campaign to selectively limit the fuels that earn credit in the Low Carbon Fuels Standard (LCFS) program. Earthjustice seems to be leading the effort. Fuels in the crosshairs are dairy biogas and biomass-based diesel. 

The provisions at the heart of what is effectively an anti-dairy and anti-biofuels campaign are reflected in a proposal submitted by CARB’s Environmental Justice (EJ) Advisory Committee. In the workshop, CARB compared outcomes for its December proposal to the EJ Committee’s proposal selectively limiting fuels from the LCFS program. 

CARB started with maximum electric vehicles (EVs) in both scenarios, in keeping with California’s commitment to electrify the transportation sector. That’s the key. Electricity does not get a smaller piece of the pie by maximizing carbon reductions with all feasible pathways. Using a pie analogy, electricity gets its piece before any other fuels even come to the table. The only question is the overall size of the low-carbon fuel pie.

With EVs as given, the analysis focused on the portion left over for liquid and gaseous fuels. A summary of the numbers tells the story:

If the LCFS can avoid more carbon emissions for less money, why wouldn’t the agency choose that? If the LCFS can further reduce the dominance of conventional diesel, how can the agency justify simply ceding the field to petroleum? If CARB cares about ‘justice’ and impacts on low-income families, how could the agency choose increasing health costs (due to more polluting emissions that disproportionately affect communities of color) and higher cost overall?

It’s hard to imagine a stronger case for CARB staying the course.