There are 4 primary differences.

1. An RFS creates a standard, and any fuel that meets that standard can compete in that market. Once a fuel has met the low-carbon standard, it becomes entirely about fuel price — a $3.00 cellulosic fuel that reduces carbon by 60% will get market share over a $3.10 cellulosic fuel that reduces carbon by 100%, because both fuels meet the cellulosic standard. In an LCFS, all fuels get credited according to the carbon reductions of their pathway. So, there are no “motivational dead zones” when it comes to pushing harder on reducing carbon

2. An LCFS sets carbon volumes, not fuel volumes. Under an LCFS....