The SAF CI utilized for RFS compliance (36.8 g CO2e×MJ -1 ) represents a 60 percent reduction in greenhouse gas emissions compared to conventional diesel fuel. This reduction threshold is meant to be broadly representative of the various pathways for producing diesel and related fuels from biomass (which result in different fuel CIs, according to EPA LCAs 43 ), and thus cannot be specifically representative of a miscanthus-to-SAF pathway that has the potential to result in a significantly lower CI. Two EPA LCAs 43 that were used to set the RFS compliance threshold (though they represent a vegetable oil-to-SAF pathway) estimated an average CI of 32.9 g CO2e×MJ -1 . Similarly to the RFS, the temporary SAF CIs (50.0 to 100.5 g CO2e×MJ -1 ; Table ) available for LCFS participation (without a new approved pathway) are meant to be representative of multiple technologies and present a very conservative estimate of emissions. However, if a new pathway were approved for participation, the LCFS-based CI (-31.8 g CO2e×MJ - 1 ) could be closer to estimates following CFR methods and spatially explicit, energy-allocated LCA.