December 27, 2022. The California Natural Gas Vehicle Coalition (CNGVC) appreciates the opportunity to provide comments to the California Air Resource Board (CARB) in response to the November 9, 2022 workshop on “Potential Modifications to the Low Carbon Fuel Standard” (Workshop).
The CNGVC supports CARB action that will continue the inclusion of renewable natural gas (RNG) as a credit-generating fuel under the Low Carbon Fuel Standard (LCFS). Such action will maintain the Program’s diversity and volume of low-carbon fuels options without arbitrary limits or radical policy changes. Accordingly, the Coalition offers the following comments in response to the Workshop proposal:
• CNGVC urges CARB to pursue a “do-no-harm” approach for biomethane as it considers “revisions” to the LCFS. It supports staff’s consideration of Alternative C for Biomethane, which will maintain the continued use of both “Avoided Methane Credits” and the “Book & Claim” process.
• They oppose any efforts to reduce or restrict RNG production, which will lead to devastating declines in private capital investment for new and existing methane reduction projects in and outside California; instability in the LCFS carbon market; increased GHG and Short-Lived Climate Pollutants (SLCP) emissions; and threaten ability to meet the state’s decarbonization goals.
• They strongly discourage limiting the use of RNG in medium- and heavy-duty (MHD) vehicles today or tomorrow. The best and highest use for RNG still remains in the HD transportation sector. Diverting RNG use away from transportation will result in continued and even increased exposure to toxic diesel pollution for the state’s most vulnerable populations adjacent to the transportation corridors. Even though RNG can yield significant and beneficial emission reductions in other industry applications, the most effective, immediate use for RNG is in the “hard-to-electrify” HD transportation sector. This use should be prioritized and any other industry uses should be secondary.
According to CNGVC, with a majority of California medium- and heavy-duty (MHD) trucks being fueled by higher-emitting diesel, the most immediate way to decarbonize the transportation sector is to displace MHD diesel trucks with renewable fuels. And, the most readily available option today is RNG. Engines powered by RNG are certified by CARB as 90% cleaner than diesel and RNG is the only negative carbon intensity fuel under the LCFS, at -33.36 gCO2e/MJ for all of 20212. California must continue to promote the production and useof ALL renewable lower carbon fuels. Lower- and negative carbon fuels, and the vehicles that use them, are critical to the state achieving its climate goals.