LCFS developments: proposal to simplify application process
On May 31, the California Air Resources Board held a workshop outlining some of its proposed changes to the low carbon fuel standard (LCFS) program. Among the changes proposed were those related to the new pathway submission and evaluation process.
CARB outlined a proposal to group all biofuels into a two-tier system. Tier 1 fuels are conventionally produced fuels, including sugar and starch based ethanol, biodiesel, renewable diesel, and natural gas produced through conventional means. Tier 2 fuels include advanced fuels such as cellulosic alcohols, biomethane, and hydrogen. A Tier 1 fuel could become a Tier 2 fuel if the facility utilizes specific innovative methods such as carbon capture and sequestration, use of renewable energy sources, reduced emissions from feedstock production, and any other innovations to increase efficiency and reduce CO2 (or equivalent) output.
Under the proposed system, CARB will provide a simplified GREET model calculator for Tier 1 fuels, and producers will be able to enter operational data at the plant such as energy consumption, yield ratios and coproduct volumes. The calculator will then provide the carbon intensity (CI) value for the facility. This will save applicants’ time and resources currently spent on creating custom GREET models for their facility and staff time currently spent on reviewing new custom GREET models and pathway applications.
Tier 1 fuel producers who have submitted new pathways, which were approved in the current system, will be grandfathered into the new system and can utilize their approved pathways to generate CI credits. They can also elect to reapply in the new system (using the GREET model calculator).
Tier 2 fuels will require a method 1 or 2 application just like they do now. They will either utilize an established Lookup Table value (Method 1), or use an existing pathway as a reference (Method 2A), or create a brand new pathway to be utilized (Method 2B). Producers wishing to use the Method 2A application process will need to meet substantiality requirements, which are dependent on the CI value for their fuel relative to the reference pathway. The requirements are proportional: the new pathway must be 5.5 percent below the reference for pathways over a CI of 20gCO2e/MJ, or 1gCO2e/MJ below pathways under a CI of 20.
CARB is still working out the finer details of the new process and is seeking comments to make the system as strong as possible. Proposed changes and notes from the workshops are available at the LCFS website. To submit comments, you can contact the LCFS staff.
Author: John Sens
Compliance Specialist, EcoEngineers