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Friday, 16 February, 2024

Raise Your Voice on California Jet Fuel Regulatory Proposal; Comments Due Feb 20

The California Air Resources Board (CARB) has proposed changes to the Low Carbon Fuel Standard (LCFS) that would remove the Standard’s original exemption for jet fuel.

Key Proposal Details

  • Jet fuels would be regulated for intrastate flights. 
    • Alternatives to jet fuel historically have counted as a credit, while not penalizing jet fuel use. This amendment would now consider jet fuel use as a demerit.
    • The proposed change would likely increase the price of jet fuel.
    • Current sustainable aviation fuel (SAF) production is insufficient to meet the new demand created by the proposed change.
  • Jet fuel composition cannot be altered under federal law and protections.
    • Federal law preempts jet fuel, which safeguards companies that import, refine, and distribute this fuel.
    • CARB has historically recognized jet fuel exemption under federal provisions.

NATA Response

NATA opposes the proposal to demerit jet fuel, as SAF production does not currently meet uptake and an increase in jet fuel prices will negatively impact industry. Instead, NATA supports policies that will increase the production and supply of SAF. NATA stands as a support and resource to CARB to identify alternatives to this proposal through continued industry cooperation and communication. NATA urges you to submit comments voicing your concerns and illustrating the unique operating environment of our industry.


Industry Next Steps and Resources

Comments on the proposal are due February 20. A hearing previously scheduled for March 21 has been postponed indefinitely. Comments can be submitted via the LCFS website until midnight February 20.


Sample Draft

NATA encourages all industry partners and members to voice their concerns by February 20th. A sample comment for industry representatives to utilize could include:

“As a representative of (INSERT California based aviation business) with xx employees throughout the state, I am opposed to the CARB proposal to eliminate the LCFS’s current exemption of jet fuel due to the following concerns.

  1. The new amendment would increase the current price of jet fuel, negatively impacting the aviation industry’s economic impact.
  2. Jet fuel was originally recognized by CARB as exempted. This change would increase company demerits if jet fuel were used, negatively impacting overall company goals.
  3. SAF production does not match current fuel uptake rates, and this proposal would do nothing to increase SAF availability.
  4. (LIST OF CONCERNS)

We appreciate the CARB’s consideration of our comments and concerns and look forward to moving ahead to find plausible, economically viable, and mutually beneficial solutions to sustainable aviation through the state.”

Please reach out to Karen Huggard (khuggard@nata.aero) or Juliet Jordan (jjordan@nata.aero) with any additional questions you may have.

For general press inquiries, contact Shannon Chambers at 703-298-1347 or schambers@nata.aero

The National Air Transportation Association (NATA) has been the voice of aviation business for more than 80 years. Representing nearly 3,700 aviation businesses, NATA’s member companies provide a broad range of services to general aviation, the airlines and the military and NATA serves as the public policy group representing the interests of aviation businesses before Congress and the federal agencies.