Bushnell, James, Muehlegger, Erich, Rapson, David and Witcover, Julie “The End of Neutrality? LCFS, Technology Neutrality, and Stimulating the Electric Vehicle Market” (Revised July 2021) | WP-318R

Widespread electrification of the transportation sector is a key component of most strategies for deep decarbonization of the U.S. economy. While the acceptance of EVs has grown dramatically over the last decade, much of this growth has been spurred by substantial support from public funds and other related policies. Major electrification on the time scales supported in many climate policy plans will require substantial investment spurred by policy. In this whitepaper we discuss the policy options for expanding the EV market. Our particular focus is on the potential role that a Low-Carbon Fuel Standard (LCFS) can play in supporting electrification. Standards like the LCFS are typically positioned as “technology neutral”, and the LCFS itself relies upon a dense set of calculations and assumptions to rate a wide variety of fuels based upon their life-cycle carbon intensity (CI). The LCFS in California is currently directing hundreds of millions of dollars to the EV market in California. However, it is likely that for a LCFS to support the kinds of investments on a magnitude likely necessary to reach electrification goals, it may have to be altered in such fundamental ways as to no longer really function as a technology-neutral fuel standard.