Woman filling up vehicle at gas station

ISA weighs in on proposed fuel standards amendments

May 23, 2024 | Matt Herman

On April 10, 2024, the California Air Resources Board (CARB) held a workshop to address proposed amendments to the California Low Carbon Fuel Standard (LCFS) program. First created in 2010, the LCFS is now responsible for nearly half of the U.S. biomass-based diesel consumption. In fact, last quarter biodiesel and renewable diesel displaced nearly 60% of California’s fossil diesel consumption. This makes the LCFS a major market for soybean oil, and, therefore, Iowa farmers.

In response to the proposed changes and ongoing market activities, the Iowa Soybean Association (ISA) provided comments in three key areas:

  1. CARB’s proposed crop-based biofuel sustainability guardrails
  2. Indirect Land Use Change (iLUC)
  3. Waste-based feedstock carbon intensity methodology

Leading up to the workshop, the environmental community was using dubious data and the Covid-driven bull market in vegetable oil to argue that CARB should cap the use of soybean oil and other lipids used in biofuel production. The industry was successful in pushing back against this narrative. CARB presented data to all stakeholders to show that any cap on lipid-based biofuel would directly result in increased usage of fossil diesel. ISA’s comments echoed CARB’s findings that a flat cap on feedstock like lipids isn’t beneficial for California, the biofuel industry, or farmers.

In place of a cap on crop-based biofuel, CARB proposed stringent, field-level certification of corn and soybeans. The Iowa Soybean Association registered opposed to this proposal. We are opposed because the proposed certification scheme goes far beyond the scope of the program and fails to take a risk-based approach. Specifically, as written, the proposal would assign the same level of risk to farmers in developing countries as they would to U.S. farmers who operate under numerous local, state, and federal laws.

We recommended that if CARB deems additional sustainability guardrails as necessary,  they seek to utilize existing information, such as the data farmers provide to USDA each year, to minimize the disruption to farmers.

Updating modeling for soy oil feedstocks

ISA continued to express our concern with CARB’s protracted use of outdated indirect land use change (iLUC) analysis. Under the current penalty, soy-based feedstocks will be phased out of the LCFS in less than a decade, potentially sooner. This is highly concerning because on one hand, CARB is recommending stringent sustainability guardrails for U.S. soy, but on the other hand is still on track to phase-out soy-based biofuels from credit generation by 2035 or sooner.

A fresh look at so-called “waste feedstocks”

Finally, ISA requested the agency take a fresh look at what has become an alarming rise in ‘used cooking oil’ importations of Asian origin. We encouraged CARB to increase audit stringency and oversight of this feedstock to maintain market integrity. Finally, we  encouraged CARB to review its life cycle assessment (LCA) methodology for 'waste' based feedstocks as the high price of these feedstocks challenges the very concept that these are a ‘waste’. Revaluation of feedstocks like used cooking oil could increase their carbon footprint, potentially making soybean oil and other crops more competitive.

Actively engaged

Iowa Soybean Association remains committed to growing the California biofuel marketplace which has become a big demand center for crop-based biofuels. As the program grows and expands,  ISA will work to ensure that out-of-state regulators do not create burdens on farmers that will lock them out of a market or place them at a disadvantage to their peers.