Comment Log Display

Clerks' Office
California Air Resources Board
1001 I Street
Sacramento, California 95814

Re: Support for California Air Resources Board Proposal to Retain
Jet Fuel Exemption in Low Carbon Fuel Standard Program


In response to the revised Proposed Low Carbon Fuel Standard
Amendments posted on August 12th, 2024, we are writing to share our
support for the recent California Air Resources Board (CARB)
proposal to retain the jet fuel exemption under its Low Carb Fuel
Standard (LCFS) Program. Southwest Airlines supports the withdrawal
of the proposal to eliminate the jet fuel exemption and retain the
existing opt-in approach for SAF under the CARB LCFS Program.

Southwest Airlines is taking action towards addressing its carbon
emissions and achieving its goal of net zero carbon emissions by
2050, and transitioning to SAF is core to these efforts. We have
long recognized that scaling up the supply of SAF and achieving
net-zero carbon emissions by 2050 can only happen by working
collaboratively with governments and other stakeholders across
sectors. Achieving this ambition for SAF will require new and
additional policy incentives, streamlined permitting processes, and
close collaboration among governments, the aviation industry, the
fuels industry, environmental organizations and others. 

In its April 10th, 2024, workshop, CARB re-stated that a principle
objective of its regulatory proposal is to "Increase the use of
alternative jet fuel in the State". We share that objective as
reflected in our company goal to replace 10% of total jet fuel
consumption with SAF by 2030 and our US airline industry support
for the US government SAF Grand Challenge. Southwest Airlines and
our fellow airlines have clearly demonstrated a strong, enduring
market signal for affordable SAF. The challenge remains supply of
affordable SAF, not the absence of a market signal by airlines. We
strongly believe that maintaining the existing exemption for jet
fuel along with the opt-in model for SAF provides a strong
foundation to achieve our mutual objectives.

Our mutual interest is to increase SAF production, availability,
and use, and the most effective way to accomplish this is to
continue the positive, collaborative approach represented by the
existing "opt-in" mechanism developed by CARB and the aviation
community. We support CARB's decision to withdraw the proposal to
remove the exemption for jet fuel for intrastate flights, preserve
the existing opt-in approach for SAF. We look forward to the
opportunity to work with CARB and other stakeholders across the SAF
ecosystem to explore solutions which build on the existing opt-in
model of the LCFS Program. We recommend that CARB establish a joint
CARB-industry working group with stakeholders across the emerging
SAF ecosystem to explore alternative policy and voluntary proposals
to rapidly increase SAF production, availability and use in
California. We look forward to working with CARB on such measures
to accelerate SAF deployment.

Sincerely,

Ruben Zaragoza 
State & Local Affairs Director 
Southwest Airlines