Submission Number: 788
Submission ID: 11026
Submission UUID: 87a61057-455c-4bd8-918a-a443e4518c8d

Created: Thu, 05/09/2024 - 21:15
Completed: Thu, 05/09/2024 - 21:58
Changed: Mon, 05/13/2024 - 08:57

Remote IP address: 174.78.9.139
Submitted by: Anonymous
Language: English

Is draft: No

Flagged: Yes
Back To Public Comments


Submitted Comment
Jack Fleck
350 Bay Area (identification only, these comments have not been reviewed by our whole team)
LCFS should redirect its funds away from biofuels to EVs and chargers

To: California Air Resources Board 1001 I Street, Sacramento, California 95814

From: Jack Lucero Fleck, 350 Bay Area (Organization for identification purposes; our full team has not been able to review these comments)

Re: Amendments to the Low Carbon Fuel Standard
to Redirect the Low Carbon Fuel Standards (LCFS)
Program Away from Biofuels toward Electrification

The LCFS program awarded about $3.3 billion in credits in 2022. Of these $2.5 billion went to biofuels (biomethane, biodiesel, ethanol, renewable diesel) and $0.8 billion went to electrification of transportation. This paper (see attached) argues that most of LCFS credits should go to electrification.

Two key asks:
CARB directors–do not approve increases in liquid biofuel or biomethane pathways, i.e. cap these credits at existing levels.

CARB staff–review and consider these cost effectiveness calculations along with environmental and health impacts and equity considerations.

The main point of this paper (see attached) is to supplement environmental and social justice objections to biofuels by making the case that the cost effectiveness–cost per metric ton (MT) of GHGs reduced–of using LCFS credits to support electrification would be better than using credits for biofuels.

The numbers support a policy of putting a cap on all existing biomethane, biodiesel, and renewable diesel credits (with a possible exception for Used Cooking Oil as a feedstock). With this cap, existing biofuel production would continue, at least for the next few years, until it is phased out as LCFS stringency increases. Most credits would be directed to electrification, where they are more cost effective, least environmentally destructive, and most equitable–a win-win-win.

Regarding the current use of funds to support electrification, the argument of this paper is that most of the LCFS program should be directed toward helping low income people who currently need to drive many miles, i.e. gas superusers, switch to an EV. Currently most of the electricity credits go to charging with renewables and/or to biomethane, which are less cost effective ways to spend the LCFS funds.

CARB has a choice to make. The LCFS program can continue its massive biofuel subsidies, or it can redirect LCFS to focusing its credits on electric vehicles–cars, trucks and buses– as well as EV chargers. This redirection would be a great improvement for equity and environmental justice as well as for the climate.