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CARB Update


Last week was a busy week at CARB. Both the Low Carbon Fuel Standard and the Cap-and-Trade rulemaking amendments took a significant step forward. At the same time, as things were really ramping up, the Board cancelled their third regular Board Meeting in a row.


  • LCFS – CARB held an in-person workshop, in which the agenda consisted of discussion of biofuels and the compliance curve. CARB slides can be found here. There was nothing from CARB on OPGEE or innovative crude crediting. The Innovative Crude crediting is still eligible in the system. CARB’s main goal for the workshop was to defend the program and check the process box. They took a long time to say they got it mostly right, but it was clear that they are open to other changes besides the agenda topics of CI curve and crop-based biofuel sustainability. They did present options for a 7 or 9% CI compliance curve stepdown in 2025 rather than the proposed 5%.

  • CT – The Standardized Regulatory Impact Assessment, or SRIA was released last week. This is the required economic analysis for the upcoming Cap-and-Trade Rulemaking and precedes the formal regulatory package by two months. The document can be found here. It is a higher-level look at what may happen in the rulemaking process, and it is not the actual proposal. The modeling done for the rulemaking is consistent with the stringency of the last Scoping Plan Update, a 48% GHG reduction in 2030. Unlike the LCFS SRIA which had a cost/gallon for consumers, this document did not (though they have in the past). The current political climate related to gas prices is probably why the agency was silent. This officially starts the 2024 CT rulemaking, which is expected to be completed by end of the year.

For more information, contact Jon Costantino or Sean Wallentine.



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