Comment Log Display

Tuesday, February 20, 2024

Clerks' Office
California Air Resources Board
1001 I Street
Sacramento, California 95814

Subject: Please reform the Low Carbon Fuel Standard -- Proposed Low
Carbon Fuel Standard Amendments

To Governor Gavin Newsom, CARB Chair Liane M. Randolph, and CARB
Board Members:

I'm greatly concerned about the current inadequate and unjust state
of California's Low Carbon Fuel Standard (LCFS) and to implore you
to take immediate action to address the environmental injustices
embedded in the program.

Your proposed amendments to California's LCFS are a climate policy
failure that backslides on the state's role as a climate leader.
The program subsidizes combustion fuels to the tune of billions of
dollars per year and has no place in our toolkit of climate
policies for the 2020s. There is too much on the line for our
climate to get this critical program so wrong.

Governor Newsom's budget proposes significant delays and cuts of
hundreds of millions of dollars to vital zero-emission
transportation programs, which makes it all the more urgent to use
the LCFS to more fully support zero-emissions transportation.
Historically, California has thrown good money after bad, and
devoted 80% of the LCFS's $3 to 4 billion each and every year to
combustion technology. It would be unconscionable to allow these
funds to continue to languish on the climate sidelines, instead of
anchoring our transition to a zero-emissions future.

The LCFS requires California oil refiners to evolve toward less
carbon-intensive fuels, playing a pivotal role in determining the
types of fuels our state transitions to, imports, and prioritizes.
Unfortunately, the LCFS is drowning in a flood of diesel made from
soybean oil and is in need of immediate reform. The unprecedented
expansion and magnitude of soybean oil-based diesel used in
California is harming people, accelerating tropical deforestation,
and undermining the state's climate policies. California's
consumption of diesel made from vegetable oil has outstripped
sustainable sources of waste oils and fats. As a response, our fuel
is increasingly produced from soybean oil--some of it imported
directly from South America. This shift raises critical concerns
about the environmental and ethical implications of our fuel
sources.

As California consumes more soybean oil, palm oil cultivation is
expanding rapidly to replace what we import. This year, California
consumption for soybean oil for fuel is on track to reach 1.3
million metric tons, more than 10 percent of global trade in
soybean oil. Luckily, meaningful safeguards can help ensure that
California stops fueling its trucks with imported soybean oil in a
misguided effort to meet our state's climate targets.

The world has changed a lot since the implementation of the LCFS in
2009. Unlike the 2000s, we have a north star goal for our climate
and the air we breathe: zero emissions transportation. Continuing
to invest the billions in revenue from the LCFS into harmful and
polluting biofuels that end up combusted, instead of electric
vehicles powered by clean energy, hampers our efforts to fight the
climate crisis while enriching oil companies and industrial
agriculture. CARB can mitigate the impact of California's fuel
consumption on sensitive ecosystems and align our climate action
with sustainable practices by capping soybean oil-based diesel and
refocusing the LCFS on electric vehicles.

I urge you to correct your course and modernize the program by
reflecting your consensus that the only way to meet air quality
standards is through eliminating combustion altogether, not piling
on billions of dollars in lavish incentives for combustion each and
every year. By focusing on real air pollution solutions, you could
add a clean air multiplier to the credits system, especially for
public fleets that transport many people at once, would deliver
major benefits for California's air quality and throw a lifeline to
cash-strapped transit agencies that low-income Californians depend
on for mobility.

The current flaws in the LCFS, such as "avoided methane crediting"
and inaccurate life cycle assessments, not only enable pollution
but disproportionately harm low-income communities and communities
of color. Factory farms, predominantly situated in these
marginalized areas, inflict severe damage on air, water, public
health, rural economies, and overall quality of life.

I urge you to consider and prioritize the following reforms to the
LCFS:

1. Eliminate "avoided methane crediting" in 2024.
2. Address inaccuracies in the Life Cycle Assessment that ignore
associated up- and downstream greenhouse gas emissions from factory
farm gas production.
3. Remove the 10-year "grace period" for factory farm gas
producers.

CARB has a pivotal opportunity this year to adopt new rules that
align the LCFS with California's environmental justice commitments.
Environmental justice, zero emission, and climate advocates have
presented a clear alternative to the current policies that heap
lavish rewards on the biggest polluters through the Comprehensive
EJ Scenario. CARB should adopt those recommendations to stop moving
California climate policy in the wrong direction.

I urge you to correct your course and modernize the program by
reflecting your consensus that the only way to meet air quality
standards is through eliminating combustion altogether, not piling
on billions of dollars in lavish incentives for combustion each and
every year. By focusing on real air pollution solutions, you could
add a clean air multiplier to the credits system, especially for
public fleets that transport many people at once, would deliver
major benefits for California's air quality and throw a lifeline to
cash-strapped transit agencies that low-income Californians depend
on for mobility. 

California cannot meet our clean air and climate goals without
harnessing the power of the Low Carbon Fuel Standard and
overhauling this multibillion-dollar program for our zero emissions
future. Please lead the charge in demanding a future free from the
clutches of Big Oil and Big Ag. By prioritizing the well-being of
Californians over corporate profits, we can reform the LCFS to
protect communities most affected by its current flaws. Your
decisive action in this critical matter would demonstrate a
commitment to bold climate action rooted in justice. Californians
deserve no less. Please act expeditiously to reform the program to
achieve our state's ambitious goals.

Thank you for your consideration of my comments. Please do NOT add
my name to your mailing list. I will learn about future
developments on this issue from other sources.

Sincerely,
Christopher Lish
San Rafael, CA