Life Cycle Modeling for New Mexico’s Clean Transportation Fuel Program

The 2024 passage of House Bill 41 directed the New Mexico Environment Department (NMED) to establish a Clean Transportation Fuel Program (CTFP), modeled after California’s Low Carbon Fuel Standard and clean fuel programs in other states. Per New Mexico statute, the CTFP must regulate transportation fuels sold within the state based on their carbon intensity (CI)—the quantity of life cycle GHG emissions per unit of fuel energy—such that the statewide-average CI will follow an annual reduction schedule. To develop this rule, NMED needed estimates of representative CIs for transportation fuels sold in New Mexico. 

ERG supported New Mexico’s CTFP by developing an array of life cycle assessment models of transportation fuels derived from petroleum, biomass, zero-carbon electricity, and waste feedstocks. ERG coordinated with NMED’s Climate Change Bureau (CCB) to build NM-GREET, a tailored version of Argonne National Laboratory’s Greenhouse gases, Regulated Emissions, and Energy use in Technologies (GREET) model. ERG used NM-GREET to estimate representative CIs of transportation fuels sold in New Mexico, which NMED embedded directly into the CTFP rule and used to project fuel credit and deficit generation in the market over time. 

Throughout the CTFP regulatory process, ERG supported CCB in communicating with regulators and stakeholders about the life cycle modeling approach, including responding to public comments, preparing fact sheets to be handed out at its hearings before New Mexico’s Environmental Improvement Board (EIB) in Santa Fe during fall 2025, and providing expert testimony at EIB hearings. ERG also led trainings on NM-GREET. The EIB unanimously approved the CTFP rule in January 2026. New Mexico expects this program to support the deployment of clean fuels, fuel production industries, and infrastructure; the availability of jobs associated with this deployment; reductions in criteria pollutants from vehicle exhaust; and associated reductions in adverse health effects.