Graves points out that an LCFS will have an impact on fuel prices by acting as a new fuel tax. Refiners will be forced to blend increasing amounts of expensive biofuels, and this cost will be passed on to the industry and other consumers, he said.
The rule would also affect U.S. energy security, as the country would use less Canadian fuels and turn to more unstable regions around the world, Graves said.
The letter says the standard would also not reduce global carbon emissions. It would prevent U.S. refineries from refining Canadian oil sands, and Canada would likely export it to China, producing even more carbon emissions transporting that oil to China by supertanker.
Graves also noted that high-blend biodiesel interferes with truck operability, as it performs poorly in cold weather, has a lower energy content than ultra low sulfur diesel fuel and adversely impacts truck fuel economy. In addition, the lifecycle carbon emissions associated with biodiesel and whether it can qualify as a low carbon alternative to diesel are still up in the air.
Graves points to ATA's Sustainability Plan as the industry's preference for addressing carbon emissions.