CARB's LCSF biofuel accrediting arbitrarily
excludes tank-to-wheel carbon dioxide emissions
California Air Resources Board’s (CARB’s) current Low
Carbon Fuel Standard (LCFS) should no longer regulate
the exclusion of tank-to-wheel carbon
dioxide emissions in their calculation of the total carbon
intensity of refinery renewable diesel and biodiesel in their
well-to-wheel carbon intensity assessment (or
the tank-to-wake CO2 for SAF). Inclusion of
tank-to-wheel emissions for Renewable Diesel (and tank-to-wake CO2
emissions for SAF) is consistent with California’s climate
goals and AB 32, the California Global Warming Solutions Act
of 2006. The tank-to-wheel assessment for agricultural-based
biofuels should be based on the same CO2 measurement methods
as petroleum fuels.
AB 32 requires “in
law, a sharp reduction of greenhouse gas (GHG)
emissions…[which] set the stage for its transition to a
sustainable, low-carbon future”. For purposes of
greenhouse gas emissions reduction, under the LCFS for
transportation fuels and consistent with AB32, only accurate
amounts of CO2 emissions should be considered when providing GHG
reduction credits.
However, CARB’s LCFS greenhouse gas document
states that “the CO2 emitted from vehicles during biofuel
combustion is considered carbon neutral, in
accordance with IPCC and U.S. EPA GHG inventory guidelines, as the
carbon released was uptaken from the atmosphere within a short
timeframe by the plant that produced the oil. A small amount of
emissions, less than 1 g/MJ, result from the GHGs (methane and
nitrous oxide) that form during biodiesel combustion.”
[Italics mine.]
[LCFS Basics with Notes - California Air Resources
Board. https://ww2.arb.ca.gov/sites/default/files/2020-09/basics-notes.pdf]
Simply because the CO2 consumed by plant growth is
combusted during biofuel usage does not negate the fact that the
likely use of massive, yearly biofuel feedstock production on
agriculture lands results in the massive loss of natural carbon
sequestration pathways on otherwise undeveloped lands (in addition
to the carbon intensive depletion of soils in industrialized forced
biofuel feedstock agriculture).
Researchers in Mildrexler et al “analyzed forest
inventory data collected on 3,335 plots and found that large trees
play a major role in the accumulated carbon stock of these forests.
Tree AGC (kg) increases sharply with tree diameter…among
five dominant tree species. Large trees accounted for 2.0 to 3.7%
of all stems…among five tree species; but held 33 to 46% of
the total AGC stored by each species. Pooled across the five
dominant species, large trees accounted for 3% of the 636,520 trees
occurring on the inventory plots but stored 42% of the total AGC. A
recently proposed large-scale vegetation management project that
involved widespread harvest of large trees, mostly grand fir, would
have removed ∼44% of the AGC stored in these large-diameter trees,
and released a large amount of carbon dioxide to the
atmosphere.”
Large Trees Dominate Carbon Storage in
Forests East of the Cascade Crest in the United States Pacific
Northwest Front. For. Glob. Change; Forest
Management. David J. Mildrexler et
al. (05 November 2020) https://www.frontiersin.org/articles/10.3389/ffgc.2020.594274/full
The
above facts strongly argue for a policy change by CARB, that when
the agency decides the greenhouse gas credit worthiness of a
transportation fuel, the Low Carbon Fuel Standard should no longer
arbitrarily regulate the exclusion of
tank-to-wheel carbon dioxide emissions in their calculation of the
total carbon intensity of renewable diesel and biodiesel (or
the tank-to-wake CO2 for SAF).