NGVAmerica Joins Associations in Commenting on California LCFS

On Friday, NGVAmerica joined with the California Natural Gas Vehicle Coalition and the Coalition for Renewable Natural Gas to submit comments to the California Air Resources Board (CARB) in regards to planned changes to the way California evaluates the greenhouse gas benefits of transportation fuels under its Low Carbon Fuel Standard (LCFS). The LCFS requires a 10 percent reduction by 2020 in the carbon intensity of transportation fuels. Under the program, fuels with a lower carbon intensity than gasoline or diesel fuel and that otherwise exceed the targets set in the program can earn credits.

The comments respond to changes first announced back in August and more recently further clarified by staff in late September. The changes propose revising the CA GREET model. Staff has proposed updating the greenhouse gas model to support a planned reauthorization of the LCFS early next year. NGVAmerica and the other organizations listed above contend that staff is moving too quickly to update the CA GREET model, and that updating the model is not critical to reauthorization of the LCFS. Based on the information presented by staff in August, the changes will drastically alter the carbon intensity of some fuels including conventional and renewable natural gas. We have been concerned that not only is the process moving too quickly but there are significant problems with the underlying data that is being used to justify the changes. A report prepared by ICF Consulting reveals that CARB in many cases is using outdated information, has incorrectly applied conversion factors, and appears to be relying on spreadsheet runs that have numerous errors.

The primary message expressed in the letter submitted on Friday is that CARB should hold off on making any changes to the GREET model until it corrects the highlighted problems and also that it should wait until later next year when more up to date emissions data becomes available as a result of analysis that is underway. Some of this new data is expected to be released as a result of the emissions studies being conducted by EDF and natural gas companies.