RFS vs LCFS or RFS & LCFS?

Twice this week, I've been asked if we'd still need a low-carbon fuel standard if we get a renewable fuel standard as part of the current energy bill. (If you're wondering what a LCFS is, check out this excellent report from UCS for an overview.) The answer is definitely yes, but it's a good question, so here's my reasoning:

An RFS done right will establish global warming pollution thresholds for fuels derived from biomass, but these will only serve as a floor for the industry. In order to drive the industry to provide the full GHG reductions it can, we need policies that drive farmers and producers to go well beyond these floors. Furthermore, the RFS only drives biofuels into the mix, it doesn't encourage other low-carbon fuels such as electricity, natural gas, or hydrogen from natural gas nor does it discourage high-carbon fuels such as liquid coal, tar sands, or oil shale. So to move the whole fuels market in the right direction, we need a broader policy that goes beyond the RFS. In other words, we need a LCFS.

If I had to choose just one policy, it would be the LCFS. (See our fact sheet on getting biofuels right.) At the federal level, the LCFS was not politically ripe and the RFS was almost inevitable, so we decided to work to make the RFS good for biofuels and good for the environment. (See my recent post on our talking points of a good RFS.) But a lot of states including Arizona, Minnesota, New Mexico, Oregon, Washington, and the Northeast states through NESCAUM are considering a LCFS and are probably wondering if they should do an RFS, LCFS, or both. Advocates in these states will need to do a similar calculus as we have done at the federal level: If you can go directly to a LCFS, that the first best option; if not can you get a good RFS? If that's not in the cards, then trying to stop a mandate and get your state to focus on smart, performance-based incentives might be the best option.