California soliciting comments on LCFS rule overhaul

In California, the Low Carbon Fuels Standard (LCFS) is being overhauled, and the California Air Resources Board (ARB) is requesting input during the rulemaking comment period by November 17th. Two of the issues most important to the low carbon fuels industry are the carbon intensity curve and cost containment issues including a potential ceiling and floor.

Several leading members of the Low Carbon Fuels Industry have suggested that Indirect Land Use Change should not be included in the carbon intensity scores of fuels at this time. If you share this perspective, it is encouraged you use following language in your submission:

“Indirect Land Use Change (ILUC)- From a technical and policy point of view, we urge you to incorporate indirect effects into the CI score, only if and when, it is done simultaneously for all fuels. Lifecycle emission policy making is to insure that all fuels are treated equally in respect to lifecycle boundaries. To that end we recommend a 3 year process where the nascent science on indirect effects for all fuels can be fully vetted and improved upon by the academic, professional and governmental institutions working on this controversial subject. This approach is consistent with the stakeholder advisory group recommendations.”

To submit.