Policy Overview

Since an amendment in 2017, the California Air Resources Board (CARB) has incentivized the voluntary capture and use of methane from dairy and livestock manure under the state’s Low Carbon Fuel Standard (LCFS) regulation. The LCFS is designed to reduce the average carbon intensity of transportation fuels used in the state, in part by requiring oil and gas companies that provide fossil-based fuels to purchase credits from producers of alternative fuels with lower carbon intensities. Dairies that capture methane emissions from livestock manure using anaerobic digesters, and convert them into renewable natural gas (RNG) for use in vehicles, are eligible for crediting under the program for three 10-year “crediting periods”. The scheme relies on the baseline assumption that captured methane converted into transportation fuel would otherwise be vented to the atmosphere, meaning that manure biogas is assigned negative carbon intensity metrics, generating profitable fuel credits which digester project developers can sell.

Adopted in 2016, California Senate Bill 1383 states that as of January 2024, CARB has the legal authority to enact laws to directly regulate methane emissions from livestock manure management. The bill also calls for the immediate wind-down of the voluntary crediting mechanism as soon as this regulatory framework is in place. As part of an update aimed to align the LCFS with California’s 2022 Scoping Plan, CARB began considering timelines in August 2023 for the phaseout of avoided methane credits in favor of an emissions reductions mandate. All timelines proposed allowed dairy methane digester projects currently in operation or beginning construction before 2030 to continue benefitting from avoided methane credits.

Policy Outcome

CARB voted in a November 2024 board meeting to preserve avoided methane credits for anaerobic digester projects until 2030. After this, new projects will not be able to be certified for LCFS credits through this fuel pathway. The hearing also decided regulations which mandate methane emissions reductions from livestock manure will be adopted by 2028 for implementation by 2030, although digester projects that already exist will be eligible to continue receiving credits for three 10-year crediting periods after the policy has come into force, and any projects that begin construction by 2030 will be eligible for two crediting periods.

Policy Status

Avoided methane credits: long-term phaseout confirmed. Manure emissions capture and reduction requirements: under development (due to come into effect in 2030).

Evidence Profile

Key

opposing not supporting mixed/unclear
supporting strongly supporting

Policy Engagement Overview

The aggregated evidence of corporate and industry advocacy on the elimination of California’s LCFS avoided methane credits shows negative engagement from the fossil fuels and biogas sector, with positions advocating for the continuation of the scheme and opposing its removal.

  • RNG-specific industry associations including the American Biogas Council (ABC) and the Coalition for Renewable Natural Gas (RNG Coalition) consistently opposed CARB amendment proposals to limit avoided methane crediting. RNG Coalition urged CARB to ignore “anti-dairy” calls to end avoided methane credits in September 2023. The ABC claimed that anaerobic digestion projects are integral to achieving California’s methane reduction goals in December 2022, and called the direct regulation of dairy methane emissions outside of the LCFS “a mistake” in November 2024.
  • Oil and gas entities including Chevron, Air Liquide, and the Western States Petroleum Association (WSPA) submitted regulatory comments advocating for the scheme’s continuation. Chevron argued that avoided methane represent genuine emissions reductions in February 2024, while the WSPA suggested in May 2024 that CARB should maintain a “technology-neutral” approach in the LCFS towards the crediting.
  • Road transport industry association The Transport Project asked CARB in November 2024 to resist pressure to change course and “adopt overly prescriptive and less collaborative policies” for LCFS crediting.

Impacts on Policy Ambition

In comparing each CARB proposal to the finalized timeline, industry engagement on the policy appears to see a weakening in crediting criteria across proposals.

  • December 2023: CARB propose that existing anaerobic digester projects could continue to be certified for up to three 10-year crediting periods as usual, but crediting would be phased out in 2040 for all projects beginning construction in 2030 and beyond.
  • August 2024: Following a public comment period, CARB issued an updated proposal which would phase out crediting for new projects as of 2030, but permit existing projects or those that begin construction before 2030 to be certified for two 10-year crediting periods.
  • October 2024: After a final public comment period, a final update proposed phasing out crediting new projects after 2030, but existing projects could be certified for three crediting periods, and those beginning construction before 2030 could be certified for two.

The timeline to phase out avoided methane credits appears to have been extended. Consequently, the finalized amendment enables digester projects beginning construction before 2030 to be eligible for up to two 10-year crediting periods, effectively crediting up to 2050, which extends beyond the 2040 deadline in the initial proposal.

Policy Status

Avoided methane credits: long-term phaseout confirmed. Manure emissions capture and reduction requirements: under development (due to come into effect in 2030).

Evidence Profile

Key

opposing not supporting mixed/unclear
supporting strongly supporting

Entities Engaged on Policy

Influencemap Performance BandOrganizationPolicy PositionPolicy Engagement Intensity