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California Air Resources Board & the Low Carbon Fuel Standard

Feb 11, 2025

By Alexa Combelic, ASA director of government affairs 

Photo Credit: Allison Jenkins

While all eyes continue to focus on the future of federal biofuels policy, states on the West Coast have been developing a network of Low Carbon Fuel Standard programs. These LCFS programs are rapidly shifting the landscape of biofuel consumption and feedstock preference at a national level. 

This past autumn, biofuel policy focus shifted specifically to California, as its Air Resources Board—the administrator of the state LCFS program—worked to develop amendments to address both decreasing prices in its credit market and newer, ambitious carbon intensity benchmarking. ASA began engaging with CARB nearly three years before the final LCFS amendment vote in November 2024. At the time, this was new territory for a policy organization that traditionally focuses on the federal level, but there was no doubt the developments in California could have wide-reaching effects throughout the domestic biofuel value chain.  

The outcomes of the final amendment vote were disappointing for the domestic agricultural biofuels feedstock industry. From using outdated modeling for soybean production to capping agricultural feedstock allowances for credit production to requiring new sustainability reporting for domestic feedstocks, domestic soybeans will theoretically be receiving a triple penalty in terms of carbon intensity. 

While it may not seem like it at the outset, the CARB chair’s resolution, which was adopted during the amendment vote, shows our early engagements have helped ASA keep the door open with CARB. While not an outright win, the resolution created explicit engagement opportunities in California as the state updates its scoring for soybeans and brings ASA and others to the table while developing its new sustainability reporting requirements.  

Sentiment in California does not necessarily mirror the national narrative, especially when it comes to state LCFS policies. There are extremely vocal factions in the state that strongly oppose liquid biofuels broadly but target agricultural feedstocks most harshly. There are others who attack the program for increasingly costly fuel prices in the state. And there are those who criticize CARB for its lack of action to improve public health in heavily polluted industrialized areas with marginalized communities. What is most important to understand is that actions against soy-based feedstocks are not necessarily directly targeted but rather symptoms of the political ethos in California.  

Through our engagement with CARB, we learned how important it is to educate West Coast policymakers about the intricacies of soybean farming, processing, and the entire biofuel value chain. This is an audience that is unfamiliar with the soybean industry, which means sharing our sustainability story was incredibly important. We have made substantial progress over the past several years, which is why opportunities remain for ASA to shape policies in California.  

Many argue that LCFS programs are inherently negative for feedstocks that carry a moderate carbon intensity like soy, as the programs continuously reduce those carbon intensity targets over time, eventually pushing these feedstocks out of the market. There is no question the biofuel consumption boom in California helped drive overall demand in the market the past few years, even with shifting feedstock preferences more recently. As more states in non-soybean growing regions deliberate the concept of developing their own LCFS, soybean growers must continue to focus on soy’s sustainability story—through additional improvements in carbon intensity scoring and delivering a narrative about the benefits of a homegrown, renewable energy feedstock.