by Luke Geiver (Ethanol Producer Magazine) The California Air Resources Board has altered its Low Carbon Fuel Standard several times since first implementing the historic policy framework in 2011. In November 2024, CARB adopted a new round of program amendments on a range of issues, including a topic that has been hotly debated: biofuel feedstock-related land-use change.
In the November decision, CARB approved (12:2) implementation of what it calls “guardrails” that require fuel producers participating in the LCFS to track crop-based and forestry-based feedstocks to their point of origin. Once tracked, the feedstocks also need to be certified sustainable. At the heart of the amendment was a push by CARB to ensure that feedstock used to produce biofuels or sustainable aviation fuel does not require additional acreage.
In November, CARB said it was in favor of convening a public forum in the following 12 months on the latest science on land-use change related to transportation fuels and the impact on greenhouse gas emissions, including the most commonly used models such as the Global Trade Analysis Project. CARB said the forum, when convened, should also consider how best to mitigate any risks of harmful land-use impacts or food market conflicts identified for consideration in a future LCFS update. Industry, environmental advocacy groups, academia, government agencies and the USDA should all be included in the talks, CARB said. Such a forum had yet to be scheduled at press time.
While CARB offered up a clear land-use change examination plan in late 2024, the amendments had not fully taken effect by press time in January and the agency had not indicted when they might, except for this statement: “Because of the significant public health and welfare benefits of the proposed regulations ... the board hereby determines there is good cause for the regulations to become effective as expeditiously as possible.”
Understanding LCFS Guardrails
The new guardrails for feedstock used to produce fuel under the LCFS program are linked more directly to biomass-based diesel and sustainable aviation fuel than to corn-based ethanol, but they would still apply. In addition to the requirement to track feedstock to the point of origin, independent feedstock certification would also be needed to “ensure feedstocks aren’t undermining natural carbon stocks,” according to CARB.
Under the policy framework prior to the adoption of the November 2024 amendments, fuel pathway holders using a specified source feedstock had to maintain records showing chain of custody from the point of origin to the fuel production facility. Attestation letters were not required.
But CARB changed that view in its amendments, stating: “To ensure specified source feedstock supply chain entities provide the correct source, type and quantity of the specified source feedstock, staff proposes to require that all specified source feedstock supply chain entities maintain attestation letters for CARB-accredited verifier and CARB review.”
The requirements mean a producer needs signed letters of authenticity from a feedstock supplier on the source, type, quantity and sustainability of the feedstock.
Under CARB’s plans, the auditing process for sustainability certification necessary to participate in the LCFS would be multifaceted and could follow other sustainability certification schemes recognized by CARB. Practices under those programs include: no cultivation on areas that serve for nature protection; avoidance of damage to habitat; crops grown on suitable soils with good agricultural practices; no soil contamination or erosion; no application of fertilizer that contaminates groundwater; responsible insect treatments; and responsible waste management practices.
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In early 2024, several biofuel associations spoke out against point-of-origin tracking requirements, focusing on the cost for farmers or producers, the improbability of CARB overseeing such a process, and the irrational basis for the change to LCFS protocol if linked to land-use change.
Christopher Bliley, senior vice president of regulatory affairs for Growth Energy, said the change to protocol on the basis of links to land-use change are both legally flawed and unnecessary.
“Put simply, CARB has failed to identify any credible evidence of direct land-use conversion that could be mitigated by some form of feedstock tracking based on social, economic and environmental criteria of an unknown form and substance,” Bliley said. “As many decades of data has demonstrated, increases in bioethanol demand have consistently been met with increased yield per acre, not with increased corn acreage.” Because CARB already disincentivizes sourcing biofuel feedstocks with higher land-use change risks, creating a system to further that is unnecessary, Bliley adds.
In comments prior to the November adoption of the amendments, RFA president and CEO Geoff Cooper said the proposed sustainability requirement and the link of feedstock to land-use change were disconnected from reality and that the land-use change debate has already been debunked.
The verification system CARB would use to ensure a feedstock’s point of origin and sustainability was also a point of contention. Bliley called out the vague description CARB provided on functionality of its third-party system, adding that an unspecified system could exclude as much as 60% of the current credit-generating fuels from the LCFS program.
But Bliley argues that the sustainability audit itself falls outside the scope of the LCFS. He questions whether CARB has the authority to perform on-site visits, investigate issues and generally enforce such a range of federal, state and local rules.
Like many commenters from California, as well as outside of the state, Cooper also pointed out that the new amendments would increase fuel prices in the state as a result of decreased supply.
Before the November vote, multiple California news outlets pressed CARB on the fuel price issue, prompting the agency to hold a press conference to specifically address the concerns. Despite stating adamantly that changes to the LCFS would not impact fuel prices throughout the months leading up to its November amendment decision, the CARB board ended its legal amendment announcement documentation, stating that CARB would, in fact, review its policies in six months and ensure that gas prices were not impacted by the decision to alter the LCFS.
California Senate Minority Leader Brian Jones, R-San Diego, has already introduced a bill that would repeal the LCFS amendments adopted by CARB on the grounds that they will increase gas prices for Californians.
Missouri Attorney General Andrew Bailey also spoke out in opposition to the changes planned for the LCFS. In addition to the cap on soybean oil feedstock allowed for use under the amendments, Bailey commented on the sustainability requirements for feedstock. “CARB has initiated plans to prevent Missouri-made biofuels from entering the California market by setting a cap of 20% on soybean oil allowed for credits and adding stringent reporting requirements that could force Missouri farmers to submit sensitive information about their private operations.”
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Traceability Technology
With Verity Carbon Solutions, a platform owned and operated by Gevo Inc., farmers can get rewarded for ag-smart practices while creating trackable data on feedstock or farming practices. The system uses distributed ledger technology—like blockchain—to provide carbon scoring and accounting across the supply chain.
KBC, a global energy and process management technology company owned by Tokyo-based Yokogawa Electric Company, is now offering its production accounting services to the feedstock sector.
...
Veriflux, founded in 2020, and winner of a U.S. EPA small business innovation research program funding award, got its start creating a program to help producers track product in accordance with the RFS. But the company says it learned the demand for traceability extends well beyond the RFS.
...
Other ag retailers like Indigo Ag or Farmers Business Network have developed traceability systems to track or reward farmers for participating in sustainability programs that ensure they are adhering to practices such as no till. FBN has connected with ADM growers to help them certify their grain as sustainable.
The Low Carbon Intensity Crop program from BASF and Anew is an integrated service that helps ethanol producers source low-CI corn directly from the farmer. READ MORE
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