The following excerpt illustrates the breadth of this regulation: "The LCFS applies to all fuels (with the exception of alternative fuels—other than biofuels—provided by an exempted regulated party for transportation use at an aggregated volume of less than 420 million MJ (3.6 million gasoline gallon equivalent) per year):
- California reformulated gasoline (CARFG)
- California ultra low sulfur diesel fuel (ULSD)
- Compressed natural gas (CNG) or liquefied natural gas (LNG)
- Liquefied petroleum gas (LPG)
- Electricity
- Compressed or liquefied hydrogen
- A fuel blend containing ethanol
- A fuel blend containing biomass-based diesel
- Pure denatured ethanol (E100)
- Pure biomass-based diesel (B100)
- Any other liquid or non-liquid fuel."
It appears that, except in small volumes, Blue Fuel would fit into the final category.
According to the ARB's press release: "The regulation requires providers, refiners, importers and blenders to ensure that the fuels they provide for the California market meet an average declining standard of 'carbon intensity'. This is established by determining the sum of greenhouse gas emissions associated with the production, transportation and consumption of a fuel, also referred to as the fuel pathway."
Opposition to the new regulation has been ongoing but has intensified with its passage. From tar sands producers to biofuel developers, not only is there concern about the carbon intensity of their fuels, there is also worry that the science behind measuring the fuel pathway is still unproven and could result in certain fuels being unfairly penalized. Nonetheless, California is a large and influential market and the producers of all types of fuels—including producers of DME using conventional methods—cannot afford to ignore this further indication of the approach of the low carbon future.
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