Comment Log Display

Dear Chair Randolph:

The California Natural Gas Vehicle Coalition (CNGVC) writes to
express our strong support for the California Air Resources Board
(CARB)'s decision to reject counterproductive changes to the Low
Carbon Fuel Standards (LCFS) that would have excluded biomethane
from the program. We concur that such action would make it
exceptionally difficult for California to reach transportation
decarbonization. 

The U.N.'s Intergovernmental Panel on Climate Change warns that we
must limit the planet's warming to 1.5 degrees Celsius to avoid
irreversible, catastrophic climate change. Reducing methane
emissions--the world's second-most-abundant greenhouse gas (GHG)
and a potent Short-Lived-Climate-Pollutant (SLCP), is key to
achieving this outcome. Methane is 80 times more powerful than
carbon dioxide in trapping heat in our atmosphere, even though
methane only remains in the environment for a fraction of the time.
Therefore, we must prioritize methane reductions in order to
immediately slow global warming and exceed the internationally
recognized warming limit.  

As the world searches for an effective means to capture and reuse
methane, California's LCFS program is successfully working as
intended to achieve this goal.  As such, it remains a primary
driver for major reductions and continues to serve as a model for
other state, federal, and international proposals to achieve
greater results.  Given the program's success and the persistent
need to combat the disastrous changes to our climate, CNGVC
strongly encourages CARB to not only reject imposing fuel
preferences, but also work to increase support for the production
of all low-carbon fuels that meet the program's criteria for
negative carbon intensity. 

As a technology-neutral program, the LCFS reflects a commitment to
an "all-hands-on-deck" approach to reducing emissions, with
California's farmers, automakers, fuel producers, goods movers, and
environmental advocates all working together to combat climate
change and clean our air. The program represents a critical
component to CARB's transportation decarbonization strategy through
the production of renewable natural gas (RNG) and we encourage you
to maintain its current technology neutral, standards-based
approach.

The LCFS is effectively incenting the reductions of GHGs and
reducing the climate impact of the dairy and swine farming industry
and producing low carbon fuels. The LCFS encourages the capture of
fugitive methane emissions derived from agricultural waste. When
seized, this waste is converted from a toxic pollutant into a
valuable low-carbon fuel source: RNG.  Even the byproducts of RNG
processing--nutrient-rich solids and liquids--have value as a
fertilizer. Producing RNG from organic waste sources provides an
opportunity to double our emissions reduction impact by capturing
the methane that would have otherwise been emitted into the
atmosphere and then using it as a tool to eliminate future
emissions. 

Renewable natural gas (RNG) derived from organic waste is critical
in the fight against climate change. The transportation sector is
California's largest source of carbon dioxide, including
Short-Lived Climate Pollutants, contributing over a third of the
state's GHG emissions. Slashing SLCP emissions immediately is
necessary to prevent the irreparable warming of the planet past the
point of catastrophe. Diesel fuel is a major source of black
carbon, and the overwhelming majority of medium and heavy-duty
trucks on California's highways are powered by diesel fuel.
Displacing diesel trucks and eliminating their emissions is the
fastest and most effective way meaningfully reduce SCLPs.

RNG-fueled low NOx trucks are the cleanest technology available
today that can be deployed as a 1-for-1 replacement of
diesel-powered trucks. Nothing can reduce black carbon more
effectively than renewable fuels that displace diesel. Low NOx
trucks, fueled by RNG, are certified by CARB as 90% cleaner than
today's certified diesel and diesel particulate matter is reduced
100% by trucks that run on this renewable fuel. CNGVC believes our
state's top priority for combating climate change should be the
rapid reduction of SCLP in the near-term.

Carbon negative fuel sources, and near-zero emission vehicles, that
use them are critical tools to reduce emissions and combat climate
change. The growing consensus among scientists and advocates
combating climate change is that we must go beyond reducing
emissions to achieve our global reduction targets; we must
transition into policies prioritizing net negative emissions to
avert dangerous levels of climate change.

Based on CARB data, natural gas (RNG and fossil) was on average a
-28.17 gCO2e/MJ, which makes natural gas used as a transportation
fuel the only negative carbon intensity fuel and the lowest carbon
fuel under the LCFS. Additionally, low NOx trucks are the only
transportation technology available and ready to be deployed today
that delivers less than zero GHG emissions and RNG is the only
transportation fuel that has achieved this distinction to date.
 
CNGVC is a diverse coalition of engine and vehicle manufacturers,
fleet operators, utilities, and renewable fuel providers whose sole
focus is the reduction of criteria, toxic and greenhouse gas
pollutant emissions from the heavy-duty transportation sector.  We
are dedicated to the advancement of low NOx trucks powered by
carbon-negative renewable natural gas (RNG) as a proven solution to
immediately help the State realize its decarbonization goals. 

For these reasons, CNGVC asks that CARB retain the LCFS as a
technology-neutral program that prioritizes the developing and
deploying of the cleanest available fuels to decarbonize
California's transportation sector. We believe RNG and the sources
that can be used to produce it are a vital tool in the state's
fight to reduce emissions and improve air quality. Feel free to
contact me at nicolerice@cngvc.org if you have any questions
regarding our position.

Respectfully,

Nicole Rice, President, CNGVC