The Clean Fuel Standard: Reducing New York’s Transportation Emissions

“Our climate is changing before our eyes. The heat trapped by human-induced greenhouse gasses will warm the planet for many generations to come,” warned UN World Meteorological Organization Secretary-General Petteri Taalas in a statement on May 18, 2022. “Sea level rise, ocean heat and acidification will continue for hundreds of years unless means to remove carbon from the atmosphere are invented.”

Each passing day is a struggle against the clock in the fight against climate change, with continuous emissions increasing the already-heavy strain on the ozone layer. According to the Environmental Protection Agency (EPA), in 2020, transportation made up 27% of the total United States greenhouse gas (GHG) emissions, taking the lead over electricity and industry, and contributing to already-dangerous rising temperatures by putting out carbon dioxide emissions from petroleum-based fuel options. 

The Clean Fuels NY Coalition, led by the New York League of Conservation Voters, was formed to showcase the widespread support for New York State to create a clean fuel standard (also known as a low-carbon fuel standard) and reduce GHG emissions from the transportation sector, which accounts for 28% of overall state emissions according to the Climate Action Council’s draft scoping plan for implementing the Climate Leadership and Community Protection Act..

Because only the federal government and California can require new vehicles to meet fuel efficiency standards, New York State must address the carbon intensity of wholesale fuels in order to provide incentives for moving to electric vehicles and reduce emissions from the millions of gas- and diesel-powered vehicles that will still be on the road for decades to come. 

A clean fuel standard (as proposed in A. 862-B/S. 2962-B) requires transportation fuel suppliers to reduce the carbon intensity of their fuels by at least 20% by 2030 or purchase credits from clean fuel suppliers such that the carbon intensity of all transportation fuels used in the state is reduced by at least 20% by 2030, thereby creating a market for clean fuels, including electricity, and technology. The switch to low-carbon alternatives is a vital step in reaching the goals set out in New York’s Climate Leadership and Protection Act (CLCPA). New York isn’t the only state considering a clean fuel standard. CFS programs are already in place in California, Oregon, and Washington, and are being considered in Illinois, Minnesota, New Mexico, and other states. 

Unfortunately, there is a lot of misinformation around how a CFS would work. Let’s address the misconceptions and misrepresentations that are out there one by one.

  • The primary beneficiary of a CFS is transportation electrification. The CFS is a performance standard, meaning that it is technology-neutral and rewards the cleanest fuels the most. California’s low-carbon fuel standard funneled $500 million to transportation electrification in 2019 alone and electrification received 20% of the credits despite making up only X percent of fuel use. That’s why the New York CFS legislation has support from electric vehicle (EV) companies and EV charging companies – they know that a CFS will supercharge EV sales and the growth of the EV charging network in New York. Some opponents of the CFS want to argue about biofuels, but the fact is there is no legislation under consideration that would do more to advance electrification. 
  • Clean Fuel Standards do not significantly impact gas prices at the pump. Opponents argue that a New York CFS would increase gas prices, but studies in California and Oregon, the two states that have had CFS programs for the longest, show no correlation between the price of CFS credits and the price of a gallon of gas at the pump. 
  • Biofuels deliver real benefits for GHG reductions. Opponents of establishing a CFS argue that biofuels like renewable natural gas and biodiesel are “false solutions” that don’t deliver any real benefits. This couldn’t be further from the truth. California’s program has prevented 38 million metric tons of carbon from being emitted and has avoided the use of 13.7 billion gallons of petroleum over the life of the program. We also know that cars that run on gasoline will continue to be sold in New York until the Advanced Clean Car Rule takes effect in 2035 and trucks that run on diesel will continue to be sold in New York until the Advanced Clean Truck Rule takes effect in 2045. That means that in the 2040s, the last decade before New York’s economy needs to have net-zero GHG emissions in order to comply with the CLCPA, there will still be millions of vehicles on the road burning pure gasoline and diesel – unless we use programs like the CFS to displace those fossil fuels with much less carbon-intensive liquid biofuels. 
  • The CFS is just one of the tools we need to decarbonize the transportation sector. Opponents of a CFS claim that it does not do enough to address communities that are overburdened by transportation pollution. We agree. That’s why NYLCV supports expanding and electrifying  mass transit as well as making its service more frequent and reliable, building networks of protected bike lanes and investing in street safety, using railroads for interstate and intercity freight and cargo bikes for local deliveries wherever possible, providing rebates for the purchase of e-bikes and e-scooters, implementing congestion pricing in New York City as soon as possible, tearing down urban highways that pollute residential neighborhoods, expanding incentives for EV purchases and the buildout of the EV charging network, and a host of other policies that will reduce transportation emissions. The CFS is not a silver bullet that can single-handedly decarbonize the transportation sector, but that is not a reason to oppose a program that still has very real and very significant benefits. 
  • The CLCPA Draft Scoping Plan recognizes the important role that a CFS can play in decarbonizing transportation. Opponents of the CFS have highlighted that some members of the Climate Action Council oppose a CFS and used this to imply that the Draft Scoping Plan rejects a CFS. This is not the case. The Plan identifies a CFS as a useful tool for reducing transportation emissions by 2030 (p. 95), highlights that it “would generate resources for ZEV infrastructure” (p. 104), and notes that “since electricity in the State is an increasingly low-carbon fuel, a clean fuel standard will support decarbonization as petroleum fuel providers finance the use of electricity for transportation use” (p. 118).