Comment Log Display

Dear Dr. Laskowski,

Thank you for the opportunity to provide comments on potential
changes to the LCFS Program. The San Francisco Bay Area Rapid
Transit District (BART) is a strong and steadfast supporter of the
LCFS Program. BART owns and operates an electrified fixed-guideway
transit system along with electric vehicle charging at its parking
facilities. It has participated as an opt-in entity in the LCFS
since 2016. 

BART runs 220,000 trains a year and operates in five counties (San
Francisco, San Mateo, Alameda, Contra Costa, and Santa Clara) with
131 miles of track and 50 stations. The vast majority of BART
trains are electric, with 100% of its electricity supplied by
zero-carbon resources including solar, wind, and hydroelectric
generators. Every weekday of 2022, BART prevented an estimated
40,000 car trips and reduced California greenhouse gas (GHG)
emissions by 500,000 lbs. CO2e. 

The LCFS program is a powerful tool to meet the state's climate
goals by incentivizing use of fuels with lower carbon intensity and
switching to modes of travel such as public transit. The LCFS is
one of California's best instruments to get passengers out of cars
and reduce Vehicle Miles Traveled (VMT). BART appreciates that CARB
is considering improvements to the program to increase its ability
to reduce California's GHG emissions and provide a long-term stable
price signal to reduce the carbon intensity of transportation.

As a long-time participant in the LCFS program, BART has generated
credits and used the revenue from their sales to fund a variety of
sustainability measures. Like other transit agencies, BART is
experiencing a post-pandemic decrease in ridership and subsequent
considerable budget deficit. BART is projected to have an
approximately $300 million deficit each fiscal year between 2025
and 2027. 

Revenues from sales of LCFS credits now have an outsized importance
on BART's sustainability measures, along with its ability to
continue to provide its core train services. The recent steep
decline in the value of LCFS credits has been severely detrimental
to BART's already-troubled budget. We are encouraged that CARB is
considering changes to support the price of LCFS credits. 

In addition, BART is troubled by the inconsistent and
disadvantageous treatment of existing train systems. Pre-2011 fixed
guideways receive a fraction of the LCFS credits of post-2010 fixed
guideways. BART's newer extensions are granted 4.6 times more
credits than older ones, despite no such efficiency difference
recorded in the actual operation of newer and older railways.

BART began operations in 1972 and almost 90% of its train system
falls into the pre-2011 category. Fixed guideway systems are the
only category to be penalized in this way in the LCFS program. We
urge CARB to correct this unfair treatment. Although the railway
has been built, it is expensive to maintain full train service,
both in terms of frequency of trains and hours of operation.
Electricity is BART's second largest operating expense. BART has so
far avoided service cuts, but it is not yet clear how it will make
up for the projected budget shortfall in the coming years. BART has
continued to invest in clean power, supplying its system with 100%
carbon-free electricity for the past three years. However, as the
fiscal cliff looms, it will have to make difficult decisions about
the type of power it purchases.

Public transit is essential to California's achievement of its
climate goals. We urge CARB to correct the inequitable treatment of
fixed guideway systems within the LCFS program. None of the
amendments studied in the Standardized Regulatory Impact Assessment
(SRIA) issued on September 8, 2023 address this issue. 

In addition, we support LA Metro and Earthjustice recommendations
to create credit multipliers for projects that advance key state
and environmental justice priorities such as bus electrification.
Passengers who take transit often use several modes by connecting
bus and train trips. Each of those trips saves GHG emissions that
would result from those passengers driving cars instead.

Thank you for the opportunity to provide comments on potential
changes to the LCFS program. We look forward to continuing our work
together to support California's robust climate goals.

Sincerely,

Yuliya Shmidt
Manager of Energy
yuliya.shmidt@bart.gov
(510) 287-4835