Low-carbon fuel standard
A low-carbon fuel standard (LCFS) is an
The first low-carbon fuel standard mandate in the world was enacted by California in 2007, with specific eligibility criteria defined by the California Air Resources Board (CARB) in April 2009 but taking effect in January 2011.[3][4][5][6] Similar legislation was approved in British Columbia in April 2008,[7] and by European Union which proposed its legislation in January 2007 and which was adopted in December 2008.[8] The United Kingdom is implementing its Renewable Transport Fuel Obligation Program, which also applies the concept of low-carbon fuels.[1]
Several bills have been proposed in the
California Low-Carbon Fuel Standard
The LCFS is a mix of
Regulatory proceedings
In accordance to the
As mandated by the Executive Order, a University of California team, led by
Public consultation process
During 2008 and until the April 2009 LCFS ruling, CARB published in its website all technical reports prepared by its staff and collaborators regarding the definition and calculations related to the proposed LCFS regulation, conducted 16 public workshops, and also submitted its studies for external peer review.[23] Before the April 23, 2009 ruling, the Board held a 45-day public hearing that received 229 comments, 21 of which were presented during the Board Hearing.[24]
Controversy about indirect land use impacts
Among relevant and controversial comments submitted to CARB as public letters, on June 24, 2008, a group of 27 scientists and researchers from a number of universities and national laboratories, expressed their concerns arguing that there "is not enough hard empirical data to base any sound policy regulation in regards to the
2009 Ruling
On April 23, 2009, CARB approved the specific rules and carbon intensity reference values for the LCFS that will go into effect on January 1, 2011.
The ruling is controversial. Representatives of the US ethanol industry complained that this rule overstates the environmental effects of corn ethanol, and also criticized the inclusion of indirect effects of land-use changes as an unfair penalty to home-made corn ethanol because deforestation in the developing world is being tied to US ethanol production.[3][5][34][35][36][37] The initial reference value set for 2011 for LCFS means that Mid-west corn ethanol will not meet the California standard unless current carbon intensity is reduced.[4][6][36][38] Oil industry representatives complained that there is a cost associated to the new standard, as the LCFS will limit the use of corn ethanol blended in gasoline, thus leaving oil refiners with few available and viable options, such as sugarcane ethanol from Brazil, but this option means paying costly U.S. import tariffs.[37][38] CARB officials and environmentalists reject such scenario because they think there will be plenty of time and economic incentive to developed inexpensive biofuels, hydrogen-based fuels, even ethanol from such cellulosic materials, or new ways to make ethanol out of corn with a smaller carbon footprint.[37][38]
The only Board member who voted against the ruling explained that he had "hard time accepting the fact that we’re going to ignore the comments of 125 scientists", referring to the letter submitted by a group of scientists questioning the indirect land use change penalty. "They said the model was not good enough... to use at this time as a component part of such an historic new standard."[6] CARB adopted only one main amendment to the staff proposal to bolster the standard review process, moving up the expected date of an expert working group to report on indirect land use change from January 2012 to January 2011.[3] This change is expected to provide for a thoroughly review of the specific penalty for indirect land use change and correct it if possible. The CARB staff is also expected to report back to the Board on indirect impacts of other fuel pathways before the commencement of the standard in 2011.[6][36]
Fuels were rated based on their carbon intensity, estimated in terms of the quantity of grams of carbon dioxide equivalent released for every megajoule of energy produced for their
California carbon intensity values for gasoline and fuels that substitute for gasoline megajoule of energy produced)
| |||
---|---|---|---|
Fuel type | Carbon intensity |
Carbon intensity including land-use changes |
Comments |
Midwest ethanol |
75.10 | 105.10 | Mainly made from corn. Includes some of the plant's power coming from coal. |
California gasoline | 95.86 | 95.86 | Gasohol with 10% ethanol.
|
CARB LCFS 2011[16] | n/a | 95.61 | Maximum allowed in 2011 (initial). Might be reviewed as more studies are available. |
CARB LCFS 2020[16] | n/a | 86.27 | Maximum allowed by 2020. Might be reviewed as more studies are available. |
California ethanol | 50.70 | 80.70 | Considers plant's power coming from natural gas. |
Brazilian ethanol | 27.40 | 73.40 | Made from sugarcane and ship transport Brazil-California included |
CNG: via pipeline | 67.70 | 67.70 | North American natural gas compressed in California. |
CNG: landfill gas | 11.26 | 11.26 | Derived from landfills in California. |
Note: the complete lifecycle analysis for these fuels and others considered such as cellulosic ethanol (farmed trees and forest waste), electricity (California average electricity mix), hydrogen (gaseous hydrogen from North American natural gas) and biodiesel (soybean) are available at CARB's website (see Lifecycle Analysis) |
The LCFS standards established in CARB's rulemaking will be periodically reviewed. The first formal review will occur by January 1, 2011. Additional reviews are expected to be conducted approximately every three years thereafter, or as necessary. The 2011 review will consider the status of efforts to develop low carbon fuels, the compliance schedule, updated technical information, and provide recommendations on metrics to address the sustainable production of low carbon fuels.[31]
According to CARB's ruling, providers of transportation fuels must demonstrate that the mix of fuels they supply meet the LCFS intensity standards for each annual compliance period. They must report all fuels provided and track the fuels’ carbon intensity through a system of "credits" and "deficits." Credits are generated from fuels with lower carbon intensity than the standard. Deficits result from the use of fuels with higher carbon intensity than the standard. A fuel provider meets its compliance obligation by ensuring that amount of credits it earns (or otherwise acquires from another party) is equal to, or greater than, the deficits it has incurred. Credits and deficits are generally determined based on the amount of fuel sold, the carbon intensity of the fuel, and the efficiency by which a vehicle converts the fuel into usable energy. Credits may be banked and traded within the LCFS market to meet obligations.[16]
Two "lookup tables" (similar to the one above) and its carbon intensity values are part of the regulation, one for gasoline and another for diesel. The carbon intensity values can only be amended or expanded by regulatory amendments, and the Board delegated to the Executive Officer the responsibility to conduct the necessary rulemaking hearings and take final action on any amendments, other than amending indirect land-use change values included in the lookup tables.[31]
Latest Developments
California-Modified GREET
Pathways for megajoule of energy produced)
| |||
---|---|---|---|
Fuel type | Carbon intensity |
Carbon intensity including land-use changes |
Comments |
Average Brazilian ethanol | 27.40 | 73.40 | Baseline pathway |
Mechanized harvesting and co-product bioelectricity |
12.20 | 58.20 | Scenario 1 |
Mechanized harvesting | 20.40 | 66.40 | Scenario 2 |
Note: for all scenarios indirect land use change effects are the same and CARB estimate is 46 gCO2e/MJ.
|
On July 20, 2009, CARB published a Notice of Public Availability of modified text and availability of additional documents regarding the April 2009 rule making (Resolution 09–31), open for public comment until August 19. The supporting documents and information added to the rule making record include new pathways for
The two additional scenarios for sugarcane ethanol were requested by the Board in order to account for improved harvesting practices and the export of electricity from sugarcane ethanol plants in Brazil using energy from
In December 2009 the
In December 2011 a federal judge granted a preliminary injunction against the implementation of California's LCFS. In three separate rulings the judge rejected CARB's defense as he concluded that the state acted unconstitutionally and the regulation "impermissibly treads into the province and powers of our federal government, reaches beyond its boundaries to regulate activity wholly outside of its borders." CARB announced it intends to appeal the decision. The Ninth Circuit Court of Appeals issued a stay of the injunction on 23 April 2012 during the tendency of the litigation. In other words, the challenge to the constitutionality of the LCFS continues, but until it is resolved there is no bar on the CARB continuing to enforce the LCFS. (While the stay did not specifically authorize a return to the LCFS, CARB argued in its briefs before the Court that a stay would "permit the LCFS to go back into effect as though the injunction had never been issued". That is the approach currently taken by CARB and it continues to refine carbon intensity standards and applicability).[54]
In 2011, a provision was added to the LCFS that allows refiners to receive credits for the deployment of innovative crude production technologies, such as carbon capture and sequestration or solar steam generation.[55] Solar thermal enhanced oil recovery is a form of enhanced oil recovery (EOR), which is key to harvesting California's heavy crude.[56] Currently, California uses EOR to help produce about 60% of its crude output.[57] By using solar power instead of natural gas to create steam for EOR, solar steam generation reduces the amount of emissions produced during oil extraction, thus lowering the overall carbon intensity of crude. California currently has two solar EOR projects in operation, one in McKittrick, operated by LINN Energy (formerly Berry Petroleum) using enclosed trough technology from GlassPoint Solar, and another in Coalinga operated by Chevron Corporation using BrightSource Energy power tower technology.
CARB is currently considering an amendment to allow upstream operators to receive credits for deploying innovative crude production technologies.[58]
In 2015, California's LCFS was re-adopted in order to address some of the issues in the original proposed standard. A number of the changes were made, including updated crude provisions, a new model used to be used to calculate carbon intensity, the establishment of a "Credit Clearance" process that would take effect at the end of the year should the LCFS credit market become too competitive, and other provisions.[59]
In May 2016, the Seneca Solar Project became the first facility to start earning LCFS credits. Located in the North Midway Sunset oil field in Taft, Kern County, California, this facility met the threshold of 0.10gCO2/ MJ carbon intensity (CI) reduction.[60]
Shortly after that, in August 2016, the SB 32 was passed, which changed the target for green house gas (GHG) reduction to 40% below the levels in 1990, to be achieved by 2030.[61] It is anticipated that this will lead to the tightening of LCFS standards from 2020 all the way through 2030.[62]
In November 2017, GlassPoint announced a partnership with Aera Energy to bring its enclosed trough technology to the South Belridge Oil Field, near Bakersfield, California. When done, the facility will be California's largest solar EOR field. It is projected to produce approximately 12 million barrels of steam per year through a 850MW thermal solar steam generator. It will also cut carbon emissions from the facility by 376,000 metric tons per year.[63]
US National Low-Carbon Fuel Standard
Using California's LCFS as a model, several bills have been presented to establish a national low-carbon fuel standards at the federal level.
2007
Senators Barbara Boxer, Dianne Feinstein, and future President Barack Obama introduced in 2007 competing bills with varying versions of California's LCFS.[64]
- In March 2007, Senator Dianne Feinstein sponsored the "Clean Fuels and Vehicles Bill", which would have reduced emissions from motor vehicle fuels by 10 percent below projected levels by 2030, and would have required fuel suppliers to increase the percentage of low-carbon fuels – biodiesel, E-85 (made with cellulosic ethanol), hydrogen, electricity, and others – in the motor vehicle fuel supply.[65]
- California Senator Barbara Boxer presented on May 3, 2007, the "Advanced Clean Fuels Act of 2007". This bill was an amendment to the Clean Air Act to promote the use of advanced clean fuels that help reduce air and water pollution and protect the environment.[66]
- Then Senator Obama introduced his bill on May 7, 2007. The "National Low Carbon Fuel Standard Act of 2007" would have required fuel refineries to reduce the lifecycle greenhouse gas emissions of the transportation fuels sold in the U.S. by 5 percent in 2015 and 10 percent in 2020.[67]
2009
In March 2009, the
EPA Renewable Fuel Standard
The
On May 5, 2009, the U.S. Environmental Protection Agency (EPA) released its
An amendment was introduced in the
EISA Standards for 2010[13] | ||
---|---|---|
Fuel Category | Percentage of Fuel Required to be Renewable |
Volume of Renewable Fuel (in billion gal) |
Cellulosic biofuel | 0.004% | 0.0065 |
Biomass-based diesel | 1.10%(1) | 1.15(1) |
Total Advanced biofuel | 0.61% | 0.95 |
Renewable fuel | 8.25% | 12.95 |
Notes: (1) Combined 2009/2010 biomass-based diesel volumes applied in 2010. |
On February 3, 2010, EPA issued its final rule regarding the expanded Renewable Fuel Standard (RFS2) for 2010 and beyond.[10] The final rule revises the annual renewable fuel standards, and the required renewable fuel volume continues to increase reaching 36 billion gallons (136.3 billion liters) by 2022. For 2010, EISA set a total renewable fuel standard of 12.95 billion gallons (49.0 billion liters). This total volume, presented as a fraction of a refiner's or importer's gasoline and diesel volume, must be renewable fuel. The final 2010 standards set by EPA are shown in the table in the right side.[13]
As mandated by law, and in order to establish the fuel category for each biofuel, EPA included in its modeling direct emissions and significant indirect emissions such as
EPA also determined that
The following table summarizes the mean GHG emissions estimated and the range of variations considering that the main source of uncertainty in the life cycle analysis is the emissions related to international land use change GHG emissions.[87]
direct and indirect land use change effects and a 30-year payback period at a 0% discount rate )
| ||||
---|---|---|---|---|
Renewable fuel Pathway (for U.S. consumption) |
Mean GHG emission reduction(1) |
GHG emission reduction 95% confidence interval(2) |
EISA category |
Assumptions/comments |
Corn ethanol | 21% | 7-32% | Renewable fuel | Natural gas fired dry mill plant, drying 63% of the DGS it produces and employing corn oil fractionation technology. |
Corn biobutanol |
31% | 20-40% | Renewable fuel | Natural gas fired dry mill plant, drying 63% of the DGS it produces and employing corn oil fractionation technology. |
Sugarcane ethanol(3) | 61% | 52-71% | Advanced biofuel | Ethanol is produced and dehydrated in Brazil prior to being imported into the U.S. and the residue is not collected. GHG emissions from ocean tankers bringing ethanol from Brazil to the U.S. are included. |
switchgrass |
110% | 102-117% | Cellulosic biofuel | Ethanol produced using the biochemical process. |
Cellulosic ethanol from corn stover | 129% | No ILUC | Cellulosic biofuel | Ethanol produced using the biochemical process. Ethanol produced from agricultural residues does not have any international land use emissions. |
Soybean-based biodiesel | 57% | 22-85% | Biomass-based diesel | Plant using natural gas |
Waste grease biodiesel | 86% | No ILUC | Biomass-based diesel | Waste grease feedstock does not have any agricultural or land use emissions. |
Notes: (1) Percent reduction in lifecycle GHG emissions compared to the average lifecycle GHG for gasoline or diesel sold or distributed as transportation fuel in 2005. (2) Confidence range accounts for uncertainty in the types of land use change assumptions and the magnitude of resulting GHG emissions. (3) EPA develop a new Brazil module to model the impact of increased production of Brazilian sugarcane ethanol for use in the U.S. market and the international impacts of Brazilian sugarcane ethanol production. The Brazil module also accounts for the domestic competition between crop and pasture land uses, and allows for livestock intensification (heads of cattle per unit area of land). |
UNICA, a Brazilian ethanol producers association, welcomed the ruling and commented that they hope the classification of Brazilian sugarcane ethanol as an advanced biofuel will contribute to influence those who seek to lift the trade barriers imposed against clean energy, both in the U.S. and the rest of the world.[88][89] EPA's final ruling is expected to benefit Brazilian producers, as the blending mandate requires an increasing quota of advanced biofuels, which is not likely to be fulfill with cellulosic ethanol, and then it would force blenders to import more Brazilian sugarcane-based ethanol, despite the existing 54¢ per gallon tariff on ethanol imported directly from Brazil.[90][91]
In the case of corn-based ethanol, EPA said that manufacturers would need to use “advanced efficient technologies” during production to meet RSF2 limits.[92] The U.S. Renewable Fuels Association also welcomed the ruling, as ethanol producers "require stable federal policy that provides them the market assurances they need to commercialize new technologies." However, they complained that "EPA continues to rely on oft-challenged and unproven theories such as international indirect land use change to penalize U.S. biofuels to the advantage of imported ethanol and petroleum."[93]
Other U.S. regional proposals and programs
Eleven U.S.
A Memorandum of Understanding concerning the development of the regional low carbon fuel standard program was signed by the Governors of each State on December 30, 2009, committing the states to an economic analysis of the program, consultation with stakeholders before ruling, and a draft model rule by early 2011.[16][96][97]
The Oregon Clean Fuels Program
In 2009, Oregon's legislature authorized the state's Department of Environmental Quality to create a standard with the same essential structure as California's LCFS.[98] DEQ began full implementation of the program starting in 2016. The Oregon Clean Fuels Standard (CFS) explicitly draws on life-cycle greenhouse gas intensity calculations created or approved by the California Air Resources Board for the LCFS.
By early 2019, the path of CFS credit prices seemed to suggest some de facto linkage between the California and Oregon programs. Although Oregon's credit prices have been generally lower, Oregon has experienced a similar upward movement in prices in the 2016-2018 period, in parallel with California credit price increases.[99]
Washington Clean Fuel Standard
The state of Washington is implementing a clean fuel standard which will require carbon intensity of its transportation fuels to 20% below 2017 levels by 2034.[100]
British Columbia Low-Carbon Fuel Requirements
The
Canada Clean fuel regulations
At a national level, Canada is implementing regulations to require liquid fossil fuel providers to reduce the carbon intensity of their fuels to 15% below 2016 levels by the year 2030.[104]
Europe
Existing regulations
The EU has mainly acted to mitigate road transport greenhouse emissions mainly through its voluntary agreement on CO2 emissions from cars and subsequently through Regulation 443/2009 which sets mandatory CO2 emission limits for new cars. The EU promoted the use of biofuels through the
Other European countries have their own mandates limiting consumption of conventional fossil fuels by substituting to cleaner fuels in order to reduce greenhouse gas emissions, such as the United Kingdom Renewable Transport Fuel Obligation Program (RTFO), requiring transport fuel suppliers to ensure that 5% of all road vehicle fuel comes from sustainable renewable sources by 2010.[1][105]
UK Renewable Transport Fuel Obligation
The
Certificates can be claimed when renewable fuels are supplied and fuel duty is paid on them. At the end of the obligation period, these certificates may be redeemed to the RTFO Administrator to demonstrate compliance. Certificates can be traded, therefore, if obligated suppliers don't have enough certificates at the end of an obligation period they have to 'buy-out' the balance of their obligation by paying a buy-out price. The buy out price will be 15 pence per litre in the first two years.[1][105]
EU low-carbon fuel standard
On January 31, 2007, the European Commission (EC) proposed new standards for transport fuels to reduce full life cycle emissions by up to 10 percent between 2011 and 2020[106] This was three weeks after the California LCFS Directive was announced.[9] The EU proposal aimed to encourage the development of low-carbon fuels and biofuels, considering reductions in greenhouse gas emissions caused by the production, transport and use of the suppliers fuels.[106]
In December 2008 the
- At least 6% by 31 December 2020, compared to the EU-average level of life cycle greenhouse gas emissions per unit of energy from fossil fuels in 2010, obtained through the use of biofuels, alternative fuels and reductions in flaring and venting at production sites.
- A further 2% reduction (subject to a review) obtained through the use of environmentally friendly carbon capture and storage technologies and electric vehicles.
- An additional further 2% reduction obtained through the purchase of credits under the Clean Development Mechanism of the Kyoto Protocol.
The commission is continuing development of the EU LCFS, in particular on the methodology for fossil fuel emissions, has recently consulted[108] on various aspects of the implementation and responses have been published.[109] Further work is underway to address Indirect Land Use Change emissions. Two modelling exercises and a model comparison exercise are being carried out to better understand the scale and nature of indirect land use change due to biofuels before the Commission makes proposals to address it.
On June 10, 2010, the EC adopted guidelines explaining how the Renewable Energy Directive (RED) should be implemented, as the Directive came into effect in December 2010.
Sustainable biofuel certificates
The EC decided to request governments, industry and NGO's to set up voluntary schemes to certify biofuel sustainability for all types of biofuels, including those imported into the EU.
Environmental groups complained the measures "are too weak to halt a dramatic increase in deforestation."[112][115] According to Greenpeace "Indirect land use change impacts of biofuels (ILUC) production still are not properly addressed" because if not properly regulated, "ILUC impacts will continue causing major biodiversity loss and more greenhosuse gas emissions."[115] On the other hand, industry representatives welcomed the introduction of a certification system and some dismissed the concerns regarding the lack of criteria about ILUC.[112][116][117]UNICA, the Brazilian ethanol producers association welcome the rules more cautiously, as they consider "that gaps in the rules needed to be filled in so the "industry has a clear framework within which to operate".[116][117] Some other industry organizations also said that further clarification is needed in order to implement the Renewable Energy Directive.[117]
The EC clarified that it would publish a report on the impacts of indirect land use by the end of 2010, as requested in the Renewable Energy Directive and on the basis of recently released reports that suggest that biofuels are saving greenhouse gas emissions.[113]
Protecting untouched nature
The rules set by the Commission establish that biofuels should not be made from
Promote only biofuels with high greenhouse gas savings
The Commission reiterated that Member States have to meet binding, national targets for renewable energy and that only those biofuels with high
See also
- California Air Resources Board
- Carbon emissions reporting
- Emission standard
- Emissions trading
- Global Warming Solutions Act of 2006
- Indirect land use change impacts of biofuels
- Low-carbon economy
- Renewable transport fuel obligation
- Sustainable transport
- Zero emissions vehicle
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External links
- CARB's website for the Low-Carbon Fuel Standard Program
- CARB: Proposed Regulation to Implement the Low Carbon Fuel Standard (approved April 23, 2009)
- European Parliament "Monitoring and reduction of greenhouse gas emissions from fuels (road transport and inland waterway vessels"(approved December 17, 2008)
- Draft bill of the ‘‘American Clean Energy and Security Act of 2009’’
- EPA's Renewable Fuel Standard Program (RFS2): Regulatory Impact Analysis for RFS2 (February 2010)
- EPA's RFS2 Final rule: Greenhouse Gas Reduction Thresholds
- Text of the National Low-Carbon Fuel Standard Act of 2007, presented by Barack Obama (This bill never became law).
- Text of the Advanced Clean Fuels Act of 2007 (This bill never became law)
- DfT home site for the Renewable Transport Fuel Obligation (RTFO)
- Indirect land use impacts of biofuels (Bioenergy Wiki)
- Roundtable on Sustainable Biomaterials profile on database of market governance mechanisms
- Status Review of California's Low Carbon Fuel Standard - July 2014, Institute of Transportation Studies (ITS), University of California, Davis.
- Bonsucro profile on database of market governance mechanisms
- LCFS Credit Price Tracking (The Jacobsen Pricing Benchmark)