Comment Log Display

In October 2018 CARB began a Low Emission Diesel effort in response
to its State Implementation Plan commitments with the intent to
increase the use of Low Emission Diesel fuels in California,
resulting in reduced NOx and PM emissions relative to the use of
conventional diesel.

Staff recently issued the results of their Low Emission Diesel
Study engine test program.  All indications are that Staff have
significantly overestimated the NOx emissions benefits of renewable
diesel.  The Low Emission Diesel Study found that renewable diesel,
at best, provides only NOx equivalent emissions versus CARB Diesel
in New Technology Diesel Engines which is in stark contrast to
Staff's claims that renewable diesel reduces NOx by 5-10%.

The 2022 SIP plan must account for Staff's errored promotion of RD
as a NOx offset factor based on the Low Emission Diesel Study.  

As CARB knows, there is significant investments being made in RD
projects which are underpinned by the LCFS.  Investors don't react
well to uncertainty and CARB's LED Study data raises major concerns
associated with the use of renewable diesel.  

The LED Study findings not only impacts the future of renewable
diesel, but it also impacts the modified Alternate Diesel Fuel
regulation. 

Unfortunately, the Board's intervention is required given Staff's
rush to judgement in the implementation of the modified Alternate
Diesel Fuel regulation which the Board will recall in April of 2021
was a highly contested regulation wherein stakeholders objected to
Staff's proposed pathway.   Unbeknownst to stakeholders and the
Board, Staff were in possession of the LED Study data prior to
April 2021 which did not support implementing the modified ADF yet
withheld it.  As a result, Staff require direct Board oversight of
both the modified ADF and LED Study in order to ensure Staff make
the necessary corrections to the modified ADF and advise
stakeholders of the potential regulatory actions they may take in
response to the LED Study.  The Board should immediately direct
Staff to update it regarding this matter. 

Thank you for the opportunity to publicly comment.