The Environmental Protection Network (EPN) was launched in January 2017 to harness the expertise of former EPA career staff and confirmation-level appointees from multiple administrations to provide an informed and objective analysis, scientific rigor, and facts about the environment and EPA.

Of the many recommendations provided by the EPN, their fourth addresses both the renewable fuel standard (RFS) and the adoption of a national low carbon fuel standard (LCFS) in an effort to increase greenhouse gas (GHG) reductions.

EPN believes EPA should closely re-examine the RFS and consider potential changes to increase GHG reductions from renewable fuels.  EPN also seems to recognize that LCFS programs offer much more in regards to GHG reductions and are becoming very powerful market drivers.  EPN recommends the EPA to evaluate the adoption of a federal LCFS under the Clean Air Act (CAA), including potential interactions with other federal and state programs. Currently, California’s LCFS program is rivaling the federal RFS for market dominance.  According to EPN, “a federal LCFS could preempt state LCFS programs, and EPA should consider the pros and cons of additional state LCFSs, e.g., on a regional level.”  EPN suggests that a federal LCFS would be in addition to and not a substitute for the RFS.

EPN recommends the following early actions, including the first 100 days:

• Lay the groundwork and start to develop a strategy to ensure that over the next 10-plus years, EPA’s programs for hydrocarbon-based fuels achieve the best air quality and GHG reductions from mobile sources. This would include a close evaluation of the RFS program and the adoption of a federal LCFS under the CAA.
• Review policies for reducing GHG and criteria emissions from ocean-going vessels and aircraft, as well as for off-road sources such as construction and agriculture.

Following this advice would help enable to the federal government maintain their position as a market leader.  Not having a federal LCFS program in place puts federal programs at risk of becoming market followers and subordinated to regional LCFS programs, which are beginning to drive and shape markets for years to come.