The Low Carbon Fuel Standard Continues to Evolve

June 25, 2014 By

Link to article: https://stillwaterassociates.com/low-carbon-fuel-standard-continues-evolve-2/

June 24, 2014

by Leigh Noda

Now in its fourth year to meet a ten-year target, the Low Carbon Fuel Standard (LCFS) continues to be an evolving regulation. With the extension of the 2013 standard to 2014, and the concepts discussed below that CARB introduced in March, we see a regulatory trend of CARB expanding the potential for LCFS credit generation.

On March 7 CARB posted an LCFS Re-Adoption Concept Paper and held a workshop on March 11 that outlined the areas of change that will be developed in 2014. The areas are:

  • GHG Emissions Reductions at Refineries
  • Modification of Compliance Curves for Gasoline and Diesel Standards
  • Refinery – Specific Crude Oil Incremental Deficit Accounting (Low Complexity Refineries)
  • Fuel Pathways and Producer Facility Registration Restructure
  • Cost Containment Provision
  • Revised ILUC (Indirect Land Use Change) Values
  • Electricity Provisions for Fixed Guide-Way and Electric Forklifts
  • Low-Energy-Use Refinery Provisions
  • Innovative Technologies for Crude Oil Production
  • Revisions to OPGEE and Updates to the Crude Lookup Table
  • Enhancements to Reporting and Record-keeping Requirements
  • Enhancements to LCFS Credit Provisions
  • Enforcement Provisions

    • Since March, CARB has held workshops on many of these areas of change and has workshops scheduled for others.

    Also, in response to the State of California Court of Appeal, Fifth Appellate District opinion that the 2009 adoption of the LCFS did not meet the California Environmental Quality Act and Administrative Procedure Act, CARB has initiated the regulatory process to readopt the LCFS regulation 2014.

    With all these changes and the need to readopt the regulation, it will be a busy year for the LCFS. Again as we see a regulatory trend of CARB proposing expanding the potential for LCFS credit generation, the outlook for the LCFS will change for the near term.

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