Group urges CARB to limit biobased diesel from lipids under California LCFS
The International Council on Clean Transportation is recommending to California Air Resources Board that a cap should be placed on the volume of lipid feedstock used for biobased diesel fuel eligible under the state’s Low Carbon Fuel Standard program.
“Over the last decade, biomass-based diesel (BBD) fuels have grown from 0.4 percent of California’s diesel blend in 2011 to 32 percent in 2021, and this growth is poised to accelerate in coming years,” ICCT stated. “Although BBD can be produced from cellulosic feedstocks, lipid-based feedstocks are the primary materials used to produce fuel for the state’s BBD market.”
The group says setting a cap on lipids “would prevent California’s BBD market shifting from one that is primarily waste oil-based to one increasingly reliant on food-based fuels with the highest sustainability risks.”
ICCT further argues that a cap “would avoid global displacement of vegetable oils that would contribute to negative impacts on global food and feed markets, deforestation, cropland expansion, rising greenhouse gas emissions, and biodiversity loss.”
Soybeans, the crop from which the predominant U.S. biobased diesel feedstock is extracted, contains roughly only 20 percent oil content. The vast majority of the crushed soybean, approximately 80 percent, is protein meal mostly used for livestock feed. As a result, increasing soybean supplies helps lower feed costs and, subsequently, pork and poultry prices.
“It’s important to keep in mind in these discussions that only about 4 percent of U.S. soybean production is used to produce domestic biofuels, by weight,” Scott Gerlt, chief economist for the American Soybean Association, told Biobased Diesel Daily. “The U.S. is projected by USDA to consume more soybean oil for food this year and next year than just two years ago.”
As far as sustainability is concerned, Gerlt pointed out that the federal Renewable Fuel Standard has requirements for feedstock sourcing to ensure that acreage is not expanding around the world due to the policies.
“Biomass-based diesel using feedstocks that did not meet this standard would not be produced in the U.S., even with the LCFS credits in California,” Gerlt said. “Additionally, the modeling that California’s Air Resource Board uses to determine the carbon intensity of a feedstock takes indirect land use into account, so the framework is already designed to consider this.”
ICCT also contends that such a limit on lipid feedstocks “would ensure that the LCFS supports a balanced portfolio of low carbon transportation fuels including alternatives such as battery and hydrogen fuel cell electric vehicles, as well as liquid fuels derived from cellulosic biomass.”
According to ICCT, the cap “should be based on an analysis of feedstock availability and competing demands for vegetable oil, waste oil, and animal fats for food and other uses. … With a reasonable cap on lipid fuels, California’s LCFS will remain a model that works for other states and the federal government, encouraging efficiency in the production and use of existing credit-generating fuels while supporting innovation in novel fuels.”
A recent study conducted by LMC International commissioned by the Advanced Biofuels Association found that in order to meet the association’s goal of 21 billion gallons of biomass-based diesel in 2040, it is estimated that consumption will need to reach close to 9 billion gallons in 2030.
If 100 percent of this volume is produced from lipid feedstocks, this would require 32 million metric tons of lipids. The study concludes that, “To 2030, feedstock supplies available for use in the U.S. are more than enough to meet our forecast demand—after accounting for food.”
Gerlt pointed out the fact that there are already billions of dollars of investment in new soybean-crushing facilities and renewable diesel plants to help produce low-carbon intensity renewable diesel. “Changing the program mid-stride would potentially undercut that investment and force large financial losses,” he said. “Policy needs to be dependable and stable, otherwise the risk of investing in clean fuel projects is too high, which limits the benefits that are trying to be achieved.”
Biobased Diesel Daily is awaiting responses from several more organizations on the matter. This story will be updated when further comment is available.
Meanwhile, the full ICCT report outlining its recommendations to CARB on capping lipid feedstocks for biobased diesel under LCFS, and its reasons for suggesting this, can be found here.
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