California Air Resources Board proposal contradicts own analysis and runs counter to intent of state’s Low Carbon Fuel Standard.
The National Oilseed Processors Association (NOPA) today pushed back against an unwarranted proposal to arbitrarily cap vegetable oil feedstocks in biomass-based diesel (BBD) produced for California fuel markets. In comments filed in response to the California Air Resources Board’s (CARB) proposed 15-Day Changes to the Proposed Amendments to the Low Carbon Fuel Standard (LCFS), NOPA called on CARB to reject the imposition of a vegetable oil cap and adopt a targeted, risk-based approach to sustainability requirements.
“With the implementation of a cap on biomass-based diesel (BBD) feedstocks, a phaseout of BBD pathways, and even more restrictive and costly traceability and verification system, this proposal will only lead to more combustion of fossil diesel fuel, higher fuel prices at the pump, and poorer air quality,” wrote NOPA President & CEO Kailee Tkacz Buller.
NOPA instead urged CARB to follow its own modeling and conclusions, which specifically and clearly show that an artificial cap on vegetable oil feedstocks is scientifically unwarranted and sends the wrong signal to the market that the LCFS program is subjective and unpredictable.
“CARB should reject the imposition of a vegetable oil cap and ensure that sustainable U.S. fuels and U.S. feedstocks are not penalized at the expense of foreign imports such as Used Cooking Oil (UCO) and tallow - some of which may not be legitimate and used to fuel California instead of local U.S. grown options at the expense of the U.S farmer, the U.S. processor, and the California taxpayer,” Tkacz Buller wrote.
NOPA also called on CARB to reassess its Land Use Change (LUC) model for all feedstocks, particularly soybean oil, as the current score reflects modeling done over a decade ago. In addition, NOPA requested that CARB extend the written comment period and hold an additional public workshop given the magnitude of proposed changes and potential impact of the new proposal.
NOPA will continue to actively engage with CARB, urging the elimination of a cap on vegetable oil, adoption of a targeted, risk-based approach to implementing sustainability criteria under the LCFS, and supporting the role of agriculture in diversifying the fuel supply through more sustainable feedstocks.
Visit files.constantcontact.com to read NOPA’s comments.