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11 States move to develop a low-carbon fuel standard

Nathanael Greene

Posted January 8, 2009

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As a little New Year's Eve present to the world, 11 Northeast and Mid-Atlantic states banded together to start the process of developing a low-carbon fuel standard as part of their efforts to reduce the global warming pollution from their transportation sector. (Here are a few press releases and related stories.) This builds off of Massachusetts announcement earlier last year to launch this sort of effort.  As the framework, signed by the head of each state's environmental agency, explains:

A "low carbon fuel standard" (LCFS) is a market-based, technologically neutral policy to address the carbon content of fuels by requiring reductions in the average lifecycle GHG emissions per unit of useful energy, which the State of California plans to implement for motor vehicles.

Four interesting things to note: first, the framework repeatedly makes reference to including both the direct and indirect emissions associated with biofuels. For instance there's this line:

The undersigned states believe it is critical to understand the true contribution of renewable fuels to reducing GHG emissions, and to calculate the carbon content of fuels on a full lifecycle basis, including direct emissions and significant indirect emissions, such as those from potential land use changes that may be attributable to fuel production.

Second, Pennsylvania signed on. PA is not one of states that adopted the Regional Greenhouse Gas Initiative (RGGI), One could argue that it's easy to sign up for a framework and other thing to implement the rules that are developed pursuant to that framework. I prefer to be optimistic and hope that PA is going to finally starting to get serious about addressing global warming.

Third, it appears that the states get the idea that a LCFS is a necessary but not sufficient step to address the GHG emissions from the transportation sector. They explicitly mention controlling emissions from vehicles (and many of these states have already adopted CA's vehicle CO2 standards--the so called Pavley rules for the former CA legislator Fran Pavley that championed them) and reducing the vehicle miles traveled. There's also this line:

The states intend to be proactive in addressing biofuel sustainability issues within a LCFS, in order to prevent unintended consequences, maintain or increase carbon storage of lands and forests, and maintain and/or improve environmental quality.

I certainly hope that the states will build on this idea of proactive policies to develop a set of companion policies to go with their LCFS. These policies should jump start the best biofuels and require broad sustainability from biofuels and make electrification a real and near-term alternative to biofuels. The technology neutrality of a LCFS is only meaningful if there's more than one technology.

Fourth and finally, it's interesting to note that the letter states that an LCFS is "potentially applicable not only in transportation, but also for fuel used for heating buildings, for industrial processes, and for electricity generation." It will be interesting to see where this leads. Hopefully it's doesn't just turn into an incentive for fuel switching from oil to natural gas. While switching is good, it's not the shift away from fossil fuels that I think is a big part of the impetus behind the LCFS.

The states are relying on NESCAUM to do their analysis and help coordinate their efforts. This is good because, as I've written about before, NESCAUM has been working on this for a while. So they have more than a running start.

In closing the states note that they want to influence any federal debate and have a memorandum of understanding by the end of 2009. All I can add is right on! Let's hope that our New Year's Eve present in 2009 is the LCFS itself.

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James PeeplesJan 10 2009 09:55 AM

Mr. Greene:

Thank you for your commentary on the LCFS which I first became aware of yesterday on Huffington Post.

Having been in the biofuels business from technical, policy, and economic perspectives for 25 years, I applaud the work undertaken by California and now NESCAUM/Mid-Atlantic states to set a long-overdue LCFS. Combined with the interest in such a move by the incoming Obama administration, the timing of this could not be better or more crucial.

Having been a part of fuels standard-setting for some time, going back to the phaseout of lead from gasoline, ULSD regulation, etc., I welcome the opportunity to participate in this process.

I must admit I have selfish reasons for offering my services. For three years, I have been working with a company known as "AHL-TECH" ( which is developing and will take to market this year the world's first bioethanol-electric hybrid locomotive, the cleanest and greenest technology available.

Our design replaces diesel fuel (which 40,000 US locomotives use at the rate of 7 - 9 billion gallons annually) with bioethanol-specific "eGenSets" which use neat ethanol exclusively. Our highly-efficient design is married to reliable batteries and other computer-managed energy capturing technology to achieve EPA Tier 4 locomotive emissions levels today, not 2015 when they take effect.

The result is near zero NOx & PM, and using cellulosic bioethanol, about a 90% reduction in net CO2 compared to the diesel engines we seek to replace. Of course, every gallon of diesel fuel we replace is less coming from the Middle East or offshore, and one more gallon of biofuel made in the U.S.

Working with the railroads, AHL-TECH is ready to become a part of the solution, which in our case is a cost-effective one for our customers. The advantages of the LCFS and other incentives will no doubt help them make the switch from fossil to non-fossil fuels.

Please give our website a look and I would welcome the opportunity to present our technology to you, David Doniger, and others interested at NRDC.

I am in the DC area and can be reached at (703) 256-4497 (office).

Thanks for your and NRDC's good work.


James Peeples
Vice President

Steve LaneJan 12 2009 07:26 PM

Fran Pavley is now the recently elected CA State Senator for the 23rd District.

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