California Air Resources Board

Dear Chair Sanchez and Members of the Board:

The National Oilseed Processors Association (NOPA) appreciates the opportunity to comment on the California Air Resources Board’s (CARB) ongoing amendments to the Low Carbon Fuel Standard (LCFS). Founded in 1930, NOPA represents the U.S. soybean, canola, flaxseed, safflower seed, and sunflower seed processing industries. Our 20 member companies operate 71 oilseed processing facilities across 20 states and collectively process over 98% of all soybeans in the United States. The oils and meals produced by our members are critical to food, feed, renewable fuels, and various industrial uses.

NOPA and its members are committed to supporting California’s climate goals and ensuring that renewable fuels used within the state are sustainable, transparent, and reliably supplied. At the same time, several proposals under consideration—including the continued use of outdated land-use change (LUC/iLUC) modeling and the adoption of a cap on vegetable oil feedstocks—pose significant risks to renewable fuel production, program integrity, and the long-term success of the LCFS.

Our comments focus on two priority issues discussed in the most recent Indirect Land Use Change Workshop:

CARB’s current iLUC modeling significantly overstates impacts and no longer reflects modern agricultural realities.

A cap on vegetable oil feedstocks is impractical, economically damaging, and counterproductive to California’s climate and air quality objectives.

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1. CARB’s iLUC Modeling Framework Is Outdated and Overestimates Impacts

CARB continues to rely on LUC/iLUC modeling platforms—GTAP-BIO and AEZ-EF—built on datasets and assumptions that are more than 20 years old. These models no longer reflect the dramatic changes in U.S. agriculture, conservation practices, global trade, or land use since 2000.

As a result:

The LCFS assigns roughly half of the total carbon intensity (CI) of soybean-based biofuels to modeled iLUC emissions.

These values mischaracterize U.S. agriculture, ignoring yield increases, crop rotation improvements, reduced tillage, and soil carbon gains that have occurred over the past two decades.

Modern peer-reviewed science shows that the current iLUC factors are no longer scientifically defensible.

Recent academic and industry-accredited studies confirm substantially lower iLUC values:

Purdue University (2023): 9.11–9.78 g CO₂e/MJ

Life Cycle Associates (2025): As low as 12 g CO₂e/MJ using GTAP 2017 and updated AEZ-EF parameters

Updated modeling also shows no net forest loss in the United States associated with feedstock production and only minimal global conversion (<5,000 hectares). Soil organic carbon retention from no-till and cover cropping can reduce modeled iLUC by up to 52%, lowering CI by 2–4 g CO₂e/MJ.

Recommendation:
NOPA strongly urges CARB to initiate a Land-Use Change Model Modernization Initiative in 2026, integrating:

GTAP 2017

Updated AEZ-EF and CCLUB modules

Regional U.S. conservation practice data

Alignment with Argonne GREET 2024 methodology

Public release of modeling assumptions and datasets for independent review

Accurate, modern modeling is essential to preserving the integrity, credibility, and effectiveness of the LCFS.

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2. A Cap on Vegetable Oil Feedstocks Is Counterproductive and Risky

NOPA strongly opposes CARB’s proposal to cap vegetable oil feedstocks. The cap would:

Reduce renewable diesel and biodiesel supply, forcing increased reliance on fossil diesel.

Increase fuel costs for California consumers by constraining the most efficient, lowest-risk feedstocks.

Jeopardize air quality benefits, as CARB’s own analysis shows a 3% reduction in emissions due to the use of renewable diesel and biodiesel.

Create operational challenges for integrated crush + biodiesel facilities that cannot substitute feedstocks without major structural changes.

Current market data further demonstrates the impracticality of the cap:

Soybean and canola oil accounted for 30% of biomass-based diesel (BBD) serving California in Q1 2024.

Vegetable oil volumes have exceeded the proposed 20% cap since Q3 2022.

Renewable diesel from soy/canola oil alone has exceeded 20% since Q1 2021.

Additionally, NOPA members and new entrants have announced $6 billion in domestic investment to expand U.S. crushing capacity by nearly 30% relative to 2023—investments made to support renewable fuel demand and LCFS-driven market growth. A vegetable oil cap would undermine these investments and shift market share toward higher-risk, less transparent imports.

Recommendation:
NOPA urges CARB to withdraw the vegetable oil cap and instead adopt a targeted, risk-based framework that protects sustainability objectives without restricting essential low-carbon feedstocks.

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Conclusion

NOPA and its members are committed partners in advancing the goals of the LCFS and supporting California’s transition to cleaner, lower-carbon fuels. The state’s renewable fuel policy has delivered meaningful environmental benefits and catalyzed significant domestic investment in low-carbon feedstock production. To maintain this progress, CARB’s regulatory framework must be based on current science, realistic implementation timelines, and risk-based sustainability approaches that reflect the actual conditions of modern agriculture and global supply chains.

We respectfully urge CARB to:

Update its LUC/iLUC modeling to reflect modern agricultural data and peer-reviewed science.

Reject the vegetable oil cap, which would undermine renewable fuel supply and increase emissions.

NOPA appreciates the opportunity to provide these comments and looks forward to continued engagement with CARB as this rulemaking progresses.

Sincerely,

Devin Mogler 

President & CEO 

National Oilseed Processors Association (NOPA)