EcoEngineers’ Take on the CARB Public Workshop Transcript
On Nov. 9, 2022, the California Air Resources Board (CARB) held a public workshop discussing the need for changes to the California Low Carbon Fuel Standard (LCFS) and introducing initial modeling scenarios aimed at for further GHG reductions by 2030 and 2045. EcoEngineers President Brad Pleima, P.E., summarizes the workshop announcements in the video above and how they might affect low-carbon fuel producers participating or planning to participate in the LCFS. CARB is soliciting feedback on all proposed alternatives and crediting considerations.
Brad Pleima, P.E. (00:05):
Hey everyone. We’ve received a lot of questions about last week’s California Air Resources Board LCFS Scoping Plan Workshop. I wanted to run down the major highlights and changes of the workshop last week. First, CARB is proposing to change the goals of the program to get to a 90% reduction by 2045. This is different than the current 20% by 2030. They proposed three ways to do that, three alternatives: Alternative A, Alternative B, and Alternative C. Each of them change the that 20%, 2030 target that’s currently in place. Option A, Alternative A, is proposed to be a 25% reduction by 2030, option B is a 30% reduction by 2030, and option C is a 35% reduction by 2030. Some of the major changes that were proposed during the scoping plan last week impact RNG significantly.
So one of those, for option A and B, CARB is proposing to remove avoided methane emissions for pathways after 2030. So all of these negative CI score dairy projects … The avoided emissions would go away after 2030, and those would likely have a positive carbon intensity score. Under option C, the same status quo, same process would currently be in place, and that 2030 cap would not be there. Another big, big change for the renewable natural gas industry is changing the way CARB looks at the book and claim process. And under alternative A and alternative B, they’re proposing to remove book and claim from outside of what they call the Western Natural Gas Grid. Exactly that definition of that grid, we don’t know. But any project outside of that would not be able to book and claim RNG for CNG use into California. So very significant impacts to RNG producers.
Under option C, no proposed changes, so every project would continue to be allowed to participate in the LCFS program, assuming they have that natural gas grid connection. For other fuels, specifically in the diesel pool, alternative A and alternative B would limit the number of credits that could be produced from virgin oil feed stocks. This would’ve an impact on renewable diesel, biodiesel. Under alternative C, there was no changes to the program. It would continue to be operated the way it is. So we’ve seen a consistent theme across these three alternatives. Alternative A and B, some significant changes to how the LCFS program is implemented. Alternative C, increasing the goal by 30%, and really operating the program as it currently stands.
Here at EcoEngineers, we have a regulatory engagement team that is well-equipped to help you draft those comments, to review those comments, led by Lisa Henke, who’s our Regulatory Engagement Director. We have someone in Sacramento. John Larrea is our California Regulatory Engagement Director. Both of them and our team are ready to help you. So if you’re a renewable fuel producer and any of these will impact you, which they likely will, now’s the time to draft those comments and submit those to CARB for consideration in the full scoping plan. CARB did indicate that they would like to the rule-making certified and approved in 2023 or early 2024, and that these rules could take effect sometime in 2024.