RFA Stresses Tech-Neutral, Market-Based Approach to California Emissions Reduction

October 26, 2021

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(Renewable Fuels Association) In comments submitted late last week, the Renewable Fuels Association reminded the California Air Resources Board that the state’s path toward achieving its carbon reduction targets should be technology-neutral, inclusive of a broad array of low- and zero-carbon technologies. RFA also recommended that CARB rely on more realistic assumptions and feasible scenarios as it develops its plan to achieve statewide carbon neutrality by 2045 or sooner.

RFA submitted the comments in response to a CARB workshop on September 30, in which the agency laid out possible scenarios for meeting the long-term carbon reduction goals of Assembly Bill 32, the California Global Warming Solutions Act of 2006.

“We have learned from the success of California’s LCFS that technology-neutral and inclusive approaches driven by market-based performance standards are the most effective,” wrote RFA Vice President of Regulatory Affairs Kelly Davis. “Developing scenarios can be illustrative but should not be designed in a way to close out known and even unknown technologies that can contribute to meeting carbon neutrality goals.”

Davis also spotlighted the importance of efforts to achieve the greatest reduction of greenhouse gas emissions as soon as possible, and that ethanol can continue to play an important role for California.

“Ethanol blended into California gasoline at ten percent blends has delivered the single largest (35%) source of GHG reductions under the LCFS since its inception in 2011,” she wrote. “Higher blends of low carbon ethanol in the current gasoline pool represent the nearest term and most affordable path for immediate reductions of GHG emissions from the light-duty fleet.”

In addition, Davis told the agency that RFA supports California’s goal of carbon neutrality by 2045, and shared a letter sent to President Biden in July, signed by all RFA’s producer members, committing the industry to carbon neutrality by 2050. Many ethanol producers will achieve this result well in advance of 2050.

These new comments from RFA were submitted in addition to those filed earlier as a joint effort of RFA, Aemetis Inc., Alto Ingredients Inc., Calgren Renewable Fuels, Growth Energy, the National Corn Growers Association, Pearson Fuels, Propel, POET and RPMG. READ MORE

Climate credits for factory farm gas violate civil rights, fail to achieve climate benefits, states petition submitted to CARB (Leadership Council for Justice and Accountability)

Excerpt from Leadership Council for Justice and Accountability: Environmental justice, animal rights, and community organizations urge CARB to eliminate credits for factory farm gas in the Low Carbon Fuel Standard --

One of California’s premier climate programs, the Low Carbon Fuel Standard (LCFS), is dramatically overstating the climate benefits of using methane gas sourced from factory farms as a transportation fuel, while illegally disregarding the disproportionate environmental and health impacts that dairy digesters inflict on low-income communities and communities of color. That is the conclusion of a petition delivered to the California Air Resources Board (CARB) today by a coalition of environmental justice, animal rights and community organizations.

“Manure-to-energy projects incentivize the expansion of the largest and most polluting factory farms. That means more cows, more drinking water pollution, more air pollution, and more climate-warming methane emissions in communities that already suffer major health impacts from poor air and water quality,” said Phoebe Seaton, co-executive director with Leadership Counsel. “California’s climate programs should be incentivizing real solutions, not throwing millions at pollution pits that hurt lower income communities of color in the San Joaquin Valley and similar places throughout the country.”

The petition calls on CARB to exclude polluting factory farm-derived methane from the LCFS or amend the credit system to better account for the actual climate impact of using factory farm-generated methane as a transportation fuel and exclude those projects that entrench and exacerbate local air and water pollution. As currently formulated, the credit system overstates the emission reduction benefits of factory farm gas by failing to account for the fuel’s life-cycle emissions — from crop production, intestinal emissions and animal feed to the disposal of manure and pipeline leaks. In the petition, groups also emphasize that factory farms have been able to exploit the credit systems to “double dip” — using public dollars to subsidize the construction of dairy digesters, while also receiving millions for the credits sold through the LCFS.

“Communities feel completely blindsided by the rapid proliferation of these polluting manure-to-energy projects. We deserve to have more input when it’s our health that’s on the line, and we just aren’t seeing the benefits. What we are seeing is an entrenchment of the worst and most polluting parts of big agriculture,” said Tom Frantz, president of the Association of Irritated Residents.

In the petition, the groups identified CARB’s current program as a violation of the Civil Rights Act of 1964, asserting that the agency must consider the social costs of emissions to ensure that regulations do not cause disparate harms on the basis of race.

“Regulators have a legal responsibility to ensure that their policies do not have a discriminatory impact on the basis of race or income, and incentivizing manure-to-energy projects through LCFS fails to meet that bar. Low-income communities and communities of color disproportionately suffer the pollution burden, while these projects enrich Big Ag and Big Gas without even providing the promised climate mitigation benefits. It is not just unacceptable, it is unjust,” said Ruthie Lazenby, environmental justice clinical fellow at Vermont Law School.

In addition to incentivizing the expansion of factory farms that pollute communities, clean transportation advocates contend that LCFS credits for factory farm methane also perpetuate the false claim that compressed gas, whether it is fracked or from factory farms, is a solution for reducing smog-forming NOx and climate pollution from heavy-duty trucks. NOx pollution from methane powered vehicles is often just as high as NOx pollution from diesel trucks — and at times can be even higher

“The inclusion of credits for factory farm gas in the low carbon fuel standards perpetuates the dangerous myth that gas powered trucks are a viable alternative to electric trucks, when the reality is that switching from one polluting vehicle to another would lock in decades of unnecessary climate and air pollution,” said Paul Cort, director of Earthjustice’s Right to Zero campaign.

A failure to consider the true pollution and climate warming impacts of factory farm gas in the LCFS will impact the efficacy of other transportation pollution reduction policies insofar as they rely on LCFS investments in dairy- and swine-produced fuels. The CARB Board will consider adoption of the Mobile Source Strategy at a meeting tomorrow, which counts on increased production of factory farm gas without consideration of its air, water, and climate impacts, especially in lower income communities and communities of color.

“The pollution trading scheme creates more pollution in the San Joaquin Valley from factory farms while perversely allowing Big Oil & Gas to greenwash their fossil fuel products. Communities on both sides of the transaction suffer discrimination and pollution — an extension of the racism, exploitation and extraction embedded in the factory farm and fossil fuel systems,” said Brent Newell, senior attorney at the Public Justice Food Project.

“Factory farm gas is being used as a smokescreen for the harms inflicted on vulnerable communities nearby factory farms under the guise of sustainability. This petition with our partners is a first step toward revamping how the California Air Resources Board addresses the inflated benefit of biogas to tackle climate change,” said Stephen Wells, executive director for the Animal Legal Defense Fund.

Food & Water Watch Legal Director Tarah Heinzen said, “As long as CARB allows biogas sourced from factory farms in its Low Carbon Fuel Standard program, California is directly subsidizing the expansion of these industrial facilities, and in turn increasing the dangers they pose to our climate as well as environmental justice communities. Factory farm digesters rely on the most environmentally harmful factory farm practices to create methane, a potent greenhouse gas, and also cement our dependence on fossil fuel infrastructure. Communities on the frontlines of factory farming across the country will continue to bear the public health burden of this industry as long as biogas is included in the Low Carbon Fuel Standard.” READ MORE