On March 5, the California Air Resources Board (CARB) released a proposed regulatory action for implementation of California's Low Carbon Fuel Standard (LCFS), a policy intended to reduce greenhouse gas emissions within the transportation sector. An integral component of the LCFS is a model for measuring the greenhouse gas emissions associated with the full spectrum of transportation fuels, including petroleum fuels, natural gas, biofuels, and electric motor drives. The core of the modeling process for all of these fuels is the GREET model, which measures the direct emissions associated with the full life cycle of fuel production (from "well to wheels"). Biofuels, however, are also charged with additional emissions caused in theory from indirect market-driven effects, as determined by a new and controversial modeling paradigm. No other fuels are assessed for indirect market-driven effects at all.

On March 16, EESI submitted a letter to CARB highlighting our concern that the selective inclusion of indirect effects may degrade the value of the LCFS as an objective tool for comparing different transportation fuels and may impair its ability to effectively reduce emissions from the transportation sector. EESI sees the California rulemaking as being of national relevance, as a number of other states are in the process of drafting similar policies and will likely look to California for methodology. In addition, the U.S. Environmental Protection Agency is currently in the process of determining how to include indirect effects in rules for the implementation of the Renewable Fuel Standard, a process that shares many similarities with the process in California.

Click here to download EESI's letter in pdf format.

Click here for more information on the California LCFS.