Joint Comments on Proposed Low Carbon Fuel Standard Amendments

The Clean Air Task Force and Pacific Environment argue that proposed LCFS amendments, including strengthened carbon intensity targets and the inclusion of intrastate aviation fuel, risk driving up demand for crop-based biofuels. They warn this could lead to increased greenhouse gas emissions from land use changes and disruptions to food markets. The authors recommend volume limits on first-generation vegetable oil-based fuels, annual market impact assessments, and extending sustainability requirements to used cooking oil and waste oils.

• Proposed LCFS amendments that strengthen and extend carbon intensity benchmarks, combined with an Automatic Acceleration Mechanism, risk accelerating the demand for crop-oil based biofuels, potentially increasing greenhouse gas emissions through direct and indirect land use changes.
• The proposal to eliminate the exemption for intrastate fossil jet fuel starting in 2028 is viewed as a positive policy signal for aviation decarbonization, but it is expected to further increase demand for bio-oil based fuels because refining bio-oils is currently the only commercially viable large-scale alternative to fossil jet fuel.
• Recent data indicates a rapid increase in the use of bio-oil based diesel in California, which accounted for 60% of the state's diesel fuel market as of Q3 2023, with crop-oil based fuels specifically growing by over 350% since 2021 to reach 192 million gallons.
• The authors argue that CARB's rejection of limits on vegetable oil-derived diesel based on air quality benefits is unjustified, citing research that shows no statistical difference in particulate matter (PM) or nitrogen oxide (NOx) emissions between renewable diesel and fossil diesel in engines with modern pollution controls.
• The proposed sustainability requirement—third-party certification that feedstocks were not derived from land forested since 2008—is criticized as too narrow to prevent secondary market impacts or land conversion in feedstock origin countries, such as Argentina.

APA

Clean Air Task Force (2024). Joint Comments on Proposed Low Carbon Fuel Standard Amendments. https://cdn.catf.us/wp-content/uploads/2024/03/01151439/carb-lcfs-amendments.pdf

Chicago

Clean Air Task Force. Joint Comments on Proposed Low Carbon Fuel Standard Amendments. 2024. https://cdn.catf.us/wp-content/uploads/2024/03/01151439/carb-lcfs-amendments.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Joint Comments on Proposed Low Carbon Fuel Standard Amendments |date=20 February 2024 |url=https://cdn.catf.us/wp-content/uploads/2024/03/01151439/carb-lcfs-amendments.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2024joint, author = {{Clean Air Task Force}}, title = {{Joint Comments on Proposed Low Carbon Fuel Standard Amendments}}, publisher = {Clean Air Task Force}, year = {2024}, month = feb, url = {https://cdn.catf.us/wp-content/uploads/2024/03/01151439/carb-lcfs-amendments.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }