Fuel carbon intensity standards may not mitigate climate change

To mitigate the climate change effects of transportation, the US states of California and Oregon, the Canadian province of British Columbia, and the European Union have implemented regulations to reduce the life cycle greenhouse gas (GHG) emissions intensity of transport fuel, commonly referred to as "carbon intensity", or CI. In this article, we unpack the theory and practice of fuel CI standards, examining claims regarding climate-change mitigation. We show that these standards do not reliably mitigate climate change because estimates of GHG reductions rely primarily on models that are not designed to estimate changes in emissions and climate impacts. Some regulations incorporate models that estimate a subset of changes in emissions, but the models must project changes in global markets over decades, and there is little agreement about the best model structure or parameter values. Since multiple models and projections may be equally plausible, fuel CI is inevitably subjective and unverifiable. We conclude that regulating or taxing observable emissions would more reliably achieve emission reduction.