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CARB Seeks Public Comments on Low Carbon Fuel Credit Rule Changes

The California Air Resources Board (CARB) is holding a series of workshops to receive feedback on potential changes to the Low Carbon Fuel Standard, LCFS, program that would increase reductions in carbon intensity of alternative fuels and electricity starting in 2024.

Biodiesel, electricity, natural gas and renewable diesel are fuels supported by LCFS. CARB said the four displaced 2.7 billion gallons of petroleum fuel in 2021 accounted for the largest growth. Renewable diesel accounted for the most LCFS credits, followed by electricity and biomethane.

CARB noted in the first workshop on July 7 that LCFS is responsible for reducing the carbon intensity (CI) of diesel and gasoline fuels by 9.6 percent in 2021, beating a compliance target of 8.75 percent reduction. The LCFS compliance target reduction for CI is 10 percent this year and 20 percent by 2030.

CARB’s proposed LCFS changes, that would take effect on Jan. 1, 2024, would adjust CI targets under three different scenarios—the current target of 20 percent, 25 percent or as much as 30 percent of the baseline.

Under Gov. Gavin Newsom’s executive order 79-20 issued on Sept. 23, 2020, CARB developed the Advanced Clean Fleets regulation that is the model for the U.S. Environmental Protection Agency’s Advanced Clean Trucks proposed rule. CARB requires that all medium- and heavy-duty vehicles including school buses must be zero-emissions by 2045 “where feasible.”

Source: California Air Resources Board.
Source: California Air Resources Board.

With its workshops, CARB is asking if five-year interim CI targets are necessary between 2030 and 2045, the risks and benefits associated with setting a 2045 CI target now, and what an appropriate timeframe is for setting a target in advance.

This fall, CARB said it will use its workshops to evaluate supply and demand of alternative fuels in the state as well as the feasibility of various CI targets.

For electric buses, CARB is aiming to support the buildout and operation of zero-emissions vehicle charging by crediting direct current fast charging infrastructure (FCI) based on capacity minus dispensed energy. Infrastructure credits would decline over time as more EVs are deployed. The other consideration is for hydrogen refueling infrastructure, or HRI.

So far, there are 2,690 approved DC fast chargers at 410 sites across California, CARB said.

CARB is also considering the role LCFS credits should play in building out infrastructure, namely if they should be focused on dedicated fleet refueling or public refueling. In terms of the level of support given, CARB seeks to answer questions on how many possible FCI and HRI credits should be available, the appropriate crediting period for incentivizing long-term investment and operation, and how large stations should be in an initial network of stations relative to refueling demand.

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CARB provided design considerations for publicly charging medium- and heavy-duty vehicles. They must be publicly accessible and primarily serve MHD vehicles, which resulted in a question of what connector types must be supported.

Total credits will be 2.5 percent of the previous quarter deficits, which was roughly 5.15 million metric tons for the first quarter of this year. Crediting periods will cover five years or when total FCI revenue exceeds capital expenses for the station, whichever comes first. CARB is asking for the expected capital expense costs of stations.

CARB is also seeking to understand any potential risks of the increased use of crop-based biofuels for such approved fuels as renewable diesel and data sources or studies, since it said that Oregon, Washington, Canada, Brazil and the EU are likely to increase global demand.

CARB is asking if it should evaluate potential impacts of future growth in crop-based biofuels. For example, CARB is asking if staff should consider a cap on crop-based biofuels. If so, what mechanisms could staff consider or implement as part of the upcoming rulemaking?

Meanwhile, CARB said it will consider the inclusion of other fuels as an opt-in
for novel applications, such as dimethyl ether that could be combined with propane or renewable propane to bring the CI to below zero. Currently, propane alone does not meet CI standards for operation.

Public feedback is accepted online until 5 p.m. Pacific on Aug. 8.

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