Growth Energy: California LCFS Updates Stack the Deck against American Biofuels

WASHINGTON, D.C.-Growth Energy, the nation's largest biofuel trade association, submitted new comments to the California Air Resources Board (CARB) today, criticizing the board's latest updates to California's Low Carbon Fuel Standard (LCFS) for unfairly singling out American biofuels in a way that will make it hard for them to generate credits under the program. Specifically, Growth Energy objected to a proposed "sustainability certification" requirement, calling it "an unfair and unnecessary double penalty for corn starch bioethanol."

"The [economic impact analysis] (EIA) acknowledges potential direct and indirect land use change (LUC) 'is at least partially (and potentially fully) accounted for by the LUC scores added to crop-derived pathways,'" said Growth Energy Senior Vice President of Regulatory Affairs Chris Bliley in the comments. "This acknowledgement renders the need for a sustainability certification moot as potential LUC concerns for crop-based feedstocks are addressed."

Furthermore, farmers that produce corn and other crops used in the production of biofuels would be required to use climate smart agriculture practices to qualify for the "sustainability certification." However, those same farmers would still not receive any credit for the emissions-reducing impact of deploying those practices under the LCFS.

"While the most recent proposal details the 'best environmental management practices' required for biomass used in fuel pathways, and those CSA practices result in the reduction of carbon emissions, CARB continues to disregard these and other practices when factoring carbon intensity (CI) scores," Bliley added. "The use of these practices for measured carbon reduction is not new. Other state agencies are using some of these same practices to reduce the release of soil carbon in the state's natural and working lands."

"CSA practices are an important component to bioethanol's continued efforts to get to net-zero," Bliley added. "We urge CARB to recognize these practices and their carbon-reduction potential and allow CSA practices to be considered when determining a pathway's CI."

Read more about the sustainability certification and climate smart agriculture in the full comments as submitted here.