Guest Commentary written by
Dean Florez
Dean Florez is a member of the California Air Resources Board and a former state senator.
As California aggressively pursues its decarbonization goals, the Low Carbon Fuel Standard has been central in reducing greenhouse gas emissions and advancing cleaner energy. However, the latest proposed amendments to the program raise significant concerns that could hinder these objectives and place an undue burden on low-income communities.
After evaluating the economic, environmental and social implications, I cannot, in good conscience, support them.
The fuel standard program currently requires a 20% reduction in transportation fuel carbon intensity by 2030, but proposed amendments aim for a 30% cut by 2030 and 90% by 2045. While these goals align with California’s climate vision, the strategy appears flawed, with experts and advocates warning that costs may disproportionately impact disadvantaged communities.
During my eight years on the California Air Resources Board, I have consistently advocated for policies that prioritize both emissions reductions and equity. However, these proposed LCFS amendments expose economic, transparency and policy gaps that weaken their credibility and efficacy.
One of the most pressing issues is the projected economic impact. A former CARB branch director has warned that, while program-related costs to consumers are currently modest, they could rise sharply as stricter targets are enforced. We cannot assert that fuel standard credit prices do not directly impact gasoline costs because this position overlooks how costs ultimately reach consumers at the pump.
By downplaying these potential expenses, CARB risks underestimating the hardship stricter targets could impose on communities already facing high living costs.
Such increases would affect essential goods and services, as transportation costs ripple through the economy, impacting food prices, housing affordability and more. For Californians already stretched thin by escalating rents and inflation, these additional costs could become overwhelming, pushing many into deeper financial insecurity.
By not sharing vital information on the full range of possible outcomes — positive, negative and realistic — the air board risks undermining public trust.
The Environmental Justice Advisory Committee, an official advisory board, has raised strong objections, pointing to CARB’s refusal to conduct a comprehensive assessment of emissions. Without transparent analysis, the air board cannot assure the public that its policies will protect California’s most vulnerable residents.
This opacity has eroded confidence in our intentions and planning. Transparent economic assessments and cost management strategies are essential to ensuring Californians and their legislators understand the true impacts of these policies on their daily lives.
Another critical flaw is CARB’s crediting system for emissions reductions from dairy and livestock operations, which lacks sufficient oversight. By allowing such credits without stringent accountability measures, the air board risks enabling practices that actually increase pollution, undermining the very climate goals the fuel standard aims to achieve.
The continued reliance on biofuels, many of which are produced out of state, further detracts from California’s efforts, limiting local environmental and economic benefits. If the air board genuinely supported California’s climate and equity objectives, fuel standard revenue would help fund in-state electric vehicle infrastructure and other public benefits — rather than subsidies that often benefit out-of-state operations.
The environmental justice committee raised concerns about “avoided methane crediting,” which the air board plans to phase out by the 2040s. Subsidizing low-impact projects risks prolonging fossil fuel reliance and weakening LCFS goals, delaying clean air solutions for low-income, pollution-burdened communities.
For California’s climate policies to succeed, they must protect the environment while safeguarding those most susceptible to economic impacts. Effective climate action must be ambitious, inclusive, transparent and equitable. The proposed fuel standard amendments, however, fall short of these ideals, focusing on aspirational targets without a fair or clear path to achieve them.
California’s commitment to environmental progress and social justice requires a balanced approach with transparent economic assessments, fair cost distribution and a focus on disadvantaged communities. Without these adjustments, the LCFS amendments risk deepening inequality, eroding public trust and weakening our climate goals.
CARB has the opportunity to craft inclusive, accountable policies, but the proposal we’re considering Friday fails to protect both the environment and social equity. I cannot support it.