In recent amendments to the Low Carbon Fuel Standard, the California Air Resources Board has proposed giving Low Carbon Fuel Standard (LCFS) credit to hydrogen and electric vehicle fueling stations, whether or not they provide low carbon fuels and regardless of the carbon intensity of the hydrogen or power provided. BAC and other biofuels producers submitted a joint letter objecting to this proposal as it would undercut the core strength of the LCFS program, which is based solely on the lifecycle carbon intensity of fuels. Picking technology winners and losers takes away the performance (science) based foundation of the LCFS program and makes if far less likely to achieve the state’s carbon and petroleum reduction goals.
BAC provided comments on several of the proposed changes to the LCFS that would adversely affect the instate biomethane industry, including a proposed reduction in the 2020 target, proposed change to biomethane that would require it to meet pipeline standards whether or not it will be injected into a utility pipeline, carbon intensities for temporary fuel pathways that are much higher than the actual carbon intensities for biomethane projects, and other changes.
Thee California Air Resources Board has proposed major changes to the Low Carbon Fuel Standard, including changes to the 2020 and 2030 targets for carbon intensity, changes to the definition of “biomethane,” temporary carbon intensity levels for various types of fuels, and other changes that could have major impacts on biomethane development in California.
In February, the California Air Resources Board released staff proposals on how ARB would spend the proposed $363 million in Low Carbon Transportation funding (from Cap and Trade revenues) if the Legislature approves the funding later this year. The staff proposals include funding plans for Low Carbon Fuels and for Heavy Duty Vehicles. ARB is holding workshops in March to discuss the draft plans. Details about the workshops are available on ARB’s website. The staff drafts are below.
The California Air Resources Board has developed a draft plan for reducing climate pollution from the transportation sector. BAC’s comments on the draft plan focus on the need for greater transparency, specific goals for large trucks that cause a disproportionate share of emissions, focus on lifecycle emissions, and incentives for the most cost-effective emissions reductions.
The California Energy Commission administers the Alternative and Renewable Fuel and Vehicle Technology Program, which provides approximately $100 million in funding per year. At a recent staff workshop, the CEC presented its staff proposal for the biofuels portion of that funding. The staff proposal stated that its goals are are to reduce carbon intensity, increase waste based fuels and fund technology transformation. The proposed funding allocations, however, prioritize very high volume production facilities, which excludes most waste based fuels that are more distributed in nature. See BAC Comments on Biofuels Solicitation Concepts.
The California Energy Commission adopts an Integrated Energy Policy Report (IEPR) every two years and an update every other year. CEC introduced the draft 2014 Integrated Energy Policy Report in November, 2014.
BAC submitted comments to the CEC supporting biofuels, biogas and issues addressed by the 2014 IEPR. BAC makes specific recommendations to the CEC on how biofuels can provide immediate and significant GHG reductions, on the need to address pipeline access and cost issues for biogas, on the importance of leveraging funding for clean, low-carbon transportation, among other issues.
Read the Bioenergy Association of California comments here
Read the California Energy Commission 2014 draft IEPR here
Abstract to the IEPR Report:
The 2014 Integrated Energy Policy Report Update provides the results of the California Energy Commission’s assessments of a variety of energy issues currently facing California. These issues include the role of transportation in meeting state climate, air quality, and energy goals; the Alternative and Renewable Fuel and Vehicle Technology Program; current and potential funding mechanisms to advance transportation policy; the status of statewide plug-in electric vehicle infrastructure; challenges and opportunities for electric vehicle infrastructure deployment; measuring success and defining metrics within the Alternative and Renewable Fuel and Vehicle Technology Program; market transformation benefits resulting from Alternative and Renewable Fuel and Vehicle Technology Program investments; the state of hydrogen, zero-emission vehicle, biofuels, and natural gas technologies over the next ten years; transportation linkages with natural gas infrastructure; evaluation of methane emissions from the natural gas system and implications for the transportation system; changing trends in California’s sources of crude oil; the increasing use of crude-by-rail in California; the integration of environmental information in renewable energy planning processes; an update on electricity reliability planning for Southern California energy infrastructure; and an update to the electricity demand forecast.
In September 2014, the California Air Resources Board presented its draft Technology Assessment for fuels. Read BAC’s Comments on the draft assessment, urging CARB to include organic waste based fuels in its comparison of the relative emissions benefits of different transportation fuel options. BAC Comments on Technology Assessment