CARB ACTs Out Pushing the Carbon Curve to 2045
California is letting climate change policies that are aimed at carbon neutrality in 25 years get in the way of proven greenhouse gas and NOx reductions today. The latest Intergovernmental Panel on Climate Change Report stressed that just over a decade is all that remains to stop irreversible damage from climate change and that time is running out. Regardless, CARB adopted the Advance Clean Truck Rule (ACT) last week to push the carbon curve out to 2045 with the electrification of the heavy-duty fleet, too little carbon too late. CARB unanimously fumbled a chance to endorse a carbon-negative fuel strategy, coupled with near-zero NOx engines to achieve significant reductions in the near-term where it could have made a real difference to execute the Short-Lived Climate Pollutant Strategy and SB 1383 implementation.
The clean fleet and renewable natural gas (RNG) industry waged a successful battle last fall, keeping the Class 8 (11.9L engine) near-zero NOx emission trucks in the Heavy-Duty Incentive Program (HVIP) after having been ‘graduated out’ with no money, and then told to sit on a wait list . . . We are still waiting! A strong campaign was mounted to include the near-zero definition into the ACT regulations and was lost. CARB has been pointing at the Carl Moyer Voucher Incentive Program (VIP) and the upcoming Heavy Duty Omnibus regulations for a ‘clear set of incentives’ for near-zero NOx trucks, realizing that those funds were not meant to materialize. CARB has HVIPed up and promised VIP treatment that will exclude the refuse industry; with upcoming Heavy Duty Omnibus regulations adding ominous costs without the promised incentives.
The COVID-19 recession has frustrated needed funding across the Board and agencies. Banking on a $7 billion bond measure structured for economic recovery has merit, but still needs explicit language for near-zero HVIP funding, and needs inclusion of the $300 million amendment for CalRecycle. Within this recession, CARB has masked huge electrification costs and fails to recognize the cost-effective RNG programs touted in their Annual Cap-and-Trade Report. This economic recovery needs established programs and not beachhead electrification strategies which added unneeded costs while stranding huge investments.
The industry has decades of experience and preparation on rolling out low NOx engines with in-state RNG to replace diesel fleets and meet CARB regulations. CARB asked us to get off diesel in the 2000s and we found an elegant community-scale system. Over $1 billion of public agency and private hauler borrowed/bonded investment in natural gas fleets, with hundreds of millions more dollars invested in the CNG fueling infrastructure. Another $1 billion has been invested to date in anaerobic digestion and compost facilities, to produce RNG for the fleet that collects the SB 1383 organic waste, which includes the $153 million in seed money granted by CalRecycle and the CEC. Another $2 to $3 billion will be needed by 2025 to divert organic waste from landfills and manifest a real economic recovery program.
As we deploy a reliable cost-effective, carbon-negative low NOx program now in good faith, CARB fails to see the value proposition and is playing a regulatory shell game. As the industry gears up to produce RNG from organic waste as part of the Short-Lived Climate Pollutant Strategy, CARB is instituting a series of regulatory barriers to achieving SB 1383 mandates by levying the huge cost of electrification, reducing RNG demand, and flippantly increasing the carbon intensity of RNG from negative to plus 45. The Low Carbon Fuel Standard (LCFS) designates RNG as carbon-negative NOW far ahead of the 2045 carbon neutrality goal.
Electrification has been characterized as “getting off diesel”, which the refuse industry has been financing for 20 years, where the collateral damage will be the abandoned CNG infrastructure and no further development of RNG facilities. Where CNG rhymes with fracking, RNG is fricking carbon-negative and not petroleum-based. With the ACT regulations, CARB has stymied the deployment of a dependable near-zero NOx RNG system, forcing many in the industry to stay on diesel for at least another decade, until electrification can be demonstrated to perform. CARB smugly adopted a perceived perfect 2045 strategy in the middle of a recessionary pandemic instead of allowing the common sense RNG-NZ trajectory to deliver what California really needs to flatten the carbon curve with economic recovery now.
Environmental Engineering & Advocacy
