Innovation has consistently outpaced the stringency of the California Low Carbon Fuel Standard (LCFS) program, leading to significant growth in the credit bank, credit devaluations, and heightened uncertainty stifling clean fuel investments.

Without additional stringency, the state faces lost opportunities for emission reductions. Adding an acceleration mechanism will help ensure that the LCFS can continue to send strong market signals that will drive innovation and deliver further GHG reductions.

While the LCFS program has multiple features to protect against price run-ups and credit shortfalls, no “built-in” features for over-exceedance of targets are in place.