Low Carbon Fuel Standard

Policy Engagement Overview

Long-term advocacy trends

• Airlines for America (A4A) advocated for less stringent benchmarks for SAF in California: In comments on California’s 2022 draft scoping plan, A4A recommended “maintaining the static 2019-2022” benchmark for jet fuel substitutes of 89.37 gCO2e/MJ until 2029 (rather than annual reductions from 2023), due to the “tremendous” quantity of SAF required for decarbonization and lack of other alternatives. This would result in a higher yearly benchmark as compounding reductions would not be applied. In 2029, fuels with an additional 7.75gCO2e/MJ could generate credits.

• Opposing the mandatory inclusion of intra-state jet fuel under California’s LCFS, questioning the legality of the measure: In June 2022 comments on California’s Draft 2022 Scoping Plan, A4A stated that the California Air Resources Board (CARB) cannot consider the integration of SAF as it conflicts with a superseding federal law, prohibiting CARB from subjecting conventional jet fuel to annually decreasing thresholds regardless of whether it is used for international, interstate or intrastate flights. Similarly, in March 2023 input on the February 2023 LCFS Public Workshop, A4A asserted that the state “lacks authority” to include jet fuel as a required fuel. This position was reiterated in August 2022 feedback on the July 2022 LCFS Public Workshop and January 2022 input on the December 2021 LCFS Public Workshop. Delta disclosed alignment with A4A on this position in its 2022 ESG report. 

• Opposing a cap on crop-based biofuels: In August 2022 feedback on a July 2022 Workshop, A4A urged CARB to refrain from imposing a cap on crop-based biofuels. Similarly, in March 2023 input on a February 2023 Workshop, A4A opposed a cap on crop-based biofuels while acknowledging that “biofuel production must not come at the expense of deforestation or food production”. The Renewable Fuels Association similarly stated a cap on crop-based biofuels would “chill investment in lower carbon fuel technologies” and have “no impact whatsoever” on food prices, in comments on a July 2022 Workshop.

Advocacy on the December 2023 Proposal:

45-day package

• A4A advocated against the mandatory inclusion of intra-state jet fuel. In February 2024 comments, A4A questioned the legality of the mandatory inclusion of jet fuel in the legislation, asserting the measure is prohibited by superseding federal laws, and urged California’s Air Resources Board to ‘withdraw the proposal to remove the exemption for jet fuel for intrastate flights and instead preserve the existing opt-in approach for SAF’.

• A4A unsupportive of proposed sustainability provisions. A4A’s February 2024 response appeared unsupportive of provisions to safeguard against deforestation and food insecurity from the use of crop-based biofuels, emphasizing implementation concerns with California’s proposal.

15-day package

• Aviation industry praises decision to maintain exemption on intra-state jet fuel. Following the removal of the mandatory inclusion of intra-state jet fuel, Delta Air Lines, A4A, Southwest Airlines, Alaska Airlines praised the exemption in August 2024 comments.

Second 15-day package

• RFA opposed sustainability requirements for biofuel production, stating that 'U.S. corn ethanol is not undergoing and does not pose a threat of rapid expansion, and therefore, the sustainability requirements should not apply to it.'