BAC Comments on Proposed Changes to the LCFS

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BAC submitted comments to the Air Resources Board on proposed changes to the Low Carbon Fuel Standard Program, including:

  • Support for increasing the carbon intensity requirement for 2030 and establishing 5-year interim targets between 2025 and 2045.
  • Need to prioritize fuels that reduce Short-Lived Climate Pollutants to meet the requirements of SB 1383.
  • Adopt incentives to support instate biofuels generated from organic waste.
  • Support adoption of sustainability criteria for biofuels.
  • Need to add “book and claim” for hydrogen and electricity generated from biogas, consistent with the RPS.
  • Need to accurately account for avoided landfill emissions.

Read BAC’s comments on proposed changes to the LCFS:

BAC Comments on July 2022 LCFS Staff Presentation (final)Download

California Air Board Proposes Changes to Low Carbon Fuel Standard

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The Low Carbon Fuels Standard Program has helped to reduce the carbon intensity of on-road vehicle fuels by nearly 10 percent over the last decade, largely thanks to increased biofuels production. Unfortunately, LCFS credit prices have dropped more than 50 percent, which threatens to slow California’s progress in reducing transportation climate emissions. To address the issue and better align the LCFS program with California’s climate goals, program staff presented several potential changes to the program, including increasing the required carbon reductions by 2030, including Sustainable Aviation Fuels, adopting sustainability criteria for biofuels, and more.

See the LCFS program staff presentation here.

BAC Comments on the Draft 2022 Climate Scoping Plan

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BAC submitted comments on the Draft 2022 Climate Change Scoping Plan focused on several important issues:

  1. BAC supports Alternate 3 as the Proposed Scenario, with some modifications, as
    it will provide the greatest benefits with the fewest downsides.
  2. The Proposed Scenario correctly includes bioenergy and renewable hydrogen,
    but should include specific recommendations to accelerate their use.
  3. The Proposed Scenario also correctly includes CCSU as an essential strategy to
    reduce emissions quickly and to reach carbon neutrality.
  4. The Scoping Plan should focus much more on SLCP reductions and other
    measures that benefit the climate in the near term.
  5. Analysis and recommendations should be based on lifecycle emissions rather
    than broad generalizations about different technologies, fuels, and strategies.
  6. The Scoping Plan should focus transportation and vehicle strategies on
    opportunities to reduce climate and air pollution in the near term.
  7. The Scoping Plan should provide a full and accurate assessment of technically
    available forest and agricultural waste biomass.

BAC-Comments-on-Draft-2022-Scoping-PlanDownload

CPUC Adopts Biomethane Procurement Program to Reduce Short-Lived Climate Pollutants

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The CPUC Decision requires utilities to procure 73 billion cubic feet of biomethane annually by 2030.

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CPUC Decision Calls for 1,000 MW of New, “Firm” Renewables, Including Bioenergy

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The CPUC’s Decision calls for 11,500 MW of new renewable power generation to offset the closure of California’s last nuclear power plant and several natural gas plants along the coast that use “once-through cooling.”  The Decision also calls for 1,000 MW from “firm” renewable power – bioenergy and geothermal – that is available when needed and has a capacity factor of at least 80 percent (is in operation 80% of the time throughout the year).  The new generation must be online by the end of 2026.

The requirement for firm renewable power begins on page 35 of the CPUC’s Decision on Mid-Term Reliability Procurement.

California Finalizes Organic Waste Diversion Regulations

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In 2016, California enacted Senate Bill 1383 to reduce the most damaging climate pollutants, known as Short-Lived Climate Pollutants.  The bill requires a 40 percent reduction in methane emissions and a 50 percent reduction in anthropogenic black carbon by 2030.  As part of the methane reduction requirement, the legislation requires a 75 percent reduction in organic landfill waste by 2025.  That means diverting more than 15 million tons of organic waste currently going to landfills and converting it to energy and compost instead.

CalRecycle’s regulations to implement the organic waste diversion requirements were just finalized by the state’s Office of Administrative Law.  The key provisions related to bioenergy are contained in Article 12 (beginning on page 92), which sets out requirements for local jurisdictions to procure bioenergy and/or compost generated from the diverted organic waste.

See:  CalRecycle SB 1383 regulations (final)