Dear Chair Randolph:
The California Natural Gas Vehicle Coalition
(CNGVC) writes to express our strong support for the California Air
Resources Board (CARB)’s decision to reject counterproductive
changes to the Low Carbon Fuel Standards (LCFS) that would have
excluded biomethane from the program. We concur that such action
would make it exceptionally difficult for California to reach
transportation decarbonization.
The U.N.’s Intergovernmental Panel on
Climate Change warns that we must limit the planet’s warming
to 1.5 degrees Celsius to avoid irreversible, catastrophic climate
change. Reducing methane emissions—the world’s
second-most-abundant greenhouse gas (GHG) and a potent
Short-Lived-Climate-Pollutant (SLCP), is key to achieving this
outcome. Methane is 80 times more powerful than carbon dioxide in
trapping heat in our atmosphere, even though methane only remains
in the environment for a fraction of the time. Therefore, we must
prioritize methane reductions in order to immediately slow global
warming and exceed the internationally recognized warming
limit.
As the world searches for an effective means to
capture and reuse methane, California’s LCFS program is
successfully working as intended to achieve this goal. As such, it remains a
primary driver for major reductions and continues to serve as a
model for other state, federal, and international proposals to
achieve greater results.
Given the program’s success and the persistent need to
combat the disastrous changes to our climate, CNGVC strongly
encourages CARB to not only reject imposing fuel preferences, but
also work to increase support for the production of all low-carbon
fuels that meet the program’s criteria for negative carbon
intensity.
As a technology-neutral program, the LCFS
reflects a commitment to an “all-hands-on-deck”
approach to reducing emissions, with California’s farmers,
automakers, fuel producers, goods movers, and environmental
advocates all working together to combat climate change and clean
our air. The program represents a critical component to
CARB’s transportation decarbonization strategy through the
production of renewable natural gas (RNG) and we encourage you to
maintain its current technology neutral, standards-based
approach.
The LCFS is effectively
incenting the reductions of GHGs and reducing the climate impact of
the dairy and swine farming industry and producing low carbon
fuels. The LCFS encourages the capture of fugitive methane
emissions derived from agricultural waste. When seized, this waste
is converted from a toxic pollutant into a valuable low-carbon fuel
source: RNG. Even the
byproducts of RNG processing—nutrient-rich solids and
liquids—have value as a fertilizer. Producing RNG from
organic waste sources provides an opportunity to double our
emissions reduction impact by capturing the methane that would have
otherwise been emitted into the atmosphere and then using it as a
tool to eliminate future emissions.
Renewable natural gas
(RNG) derived from organic waste is critical in the fight against
climate change. The transportation sector is California’s
largest source of carbon dioxide, including Short-Lived Climate
Pollutants, contributing over a third of the state’s GHG
emissions. Slashing SLCP emissions immediately is necessary to
prevent the irreparable warming of the planet past the point of
catastrophe. Diesel fuel is a major source of black carbon, and the
overwhelming majority of medium and heavy-duty trucks on
California’s highways are powered by diesel fuel. Displacing
diesel trucks and eliminating their emissions is the fastest and
most effective way meaningfully reduce SCLPs.
RNG-fueled low NOx trucks are the cleanest
technology available today that can be deployed as a 1-for-1
replacement of diesel-powered trucks. Nothing can reduce black
carbon more effectively than renewable fuels that displace diesel.
Low NOx trucks, fueled by RNG, are certified by CARB as 90% cleaner
than today’s certified diesel and diesel particulate matter
is reduced 100% by trucks that run on this renewable fuel. CNGVC
believes our state’s top priority for combating climate
change should be the rapid reduction of SCLP in the
near-term.
Carbon negative fuel
sources, and near-zero emission vehicles, that use them are
critical tools to reduce emissions and combat climate change.
The growing consensus among scientists and advocates
combating climate change is that we must go beyond reducing
emissions to achieve our global reduction targets; we must
transition into policies prioritizing net negative emissions to
avert dangerous levels of climate change.
Based on CARB data, natural gas (RNG and
fossil) was on average a -28.17 gCO2e/MJ, which makes natural gas
used as a transportation fuel the only negative carbon intensity
fuel and the lowest carbon fuel under the LCFS. Additionally, low
NOx trucks are the only transportation technology available and
ready to be deployed today that delivers less than zero
GHG emissions and RNG is the only transportation fuel that has
achieved this distinction to date.
CNGVC is a diverse coalition of engine and
vehicle manufacturers, fleet operators, utilities, and renewable
fuel providers whose sole focus is the reduction of criteria, toxic
and greenhouse gas pollutant emissions from the heavy-duty
transportation sector.
We are dedicated to the advancement of low NOx trucks
powered by carbon-negative renewable natural gas (RNG) as a proven
solution to immediately help the State realize its decarbonization
goals.
For these reasons, CNGVC asks that CARB retain
the LCFS as a technology-neutral program that prioritizes the
developing and deploying of the cleanest available fuels to
decarbonize California’s transportation sector. We believe
RNG and the sources that can be used to produce it are a vital tool
in the state’s fight to reduce emissions and improve air
quality. Feel free to contact me at
nicolerice@cngvc.org if you have any questions
regarding our position.