CARB Low Carbon Fuel Standard Regulation

Yorke Engineering, LLC (Yorke) has multiple California Air Resources Board (CARB) accredited Low Carbon Fuel Standard (LCFS) lead verifiers on staff. Yorke has advised hundreds of clients on various CARB programs and how these programs apply to all types of facilities. We have a good working relationship with many of the staff members at CARB and can help you navigate the LCFS Regulation.

The LCFS is designed to encourage the use and production of cleaner, low-carbon transportation fuels in California, and thereby reduce GHG emissions and decrease petroleum dependence in the transportation sector. The standard is expressed in terms of the “carbon intensity” (CI), which is a measure of carbon produced per unit of energy. Low-carbon fuels below the CI benchmark generate credits, while fuels above the benchmark generate deficits. Providers of transportation fuels must demonstrate that the mix of fuels they supply for use in California meets the LCFS benchmarks for each annual compliance period.

The LCFS rule was updated in 2019 and has numerous new provisions that affect a wide variety of facility types, greatly broadening the opportunities available to generate LCFS credits. For transportation fuel suppliers in California, LCFS creates a compliance obligation, and Yorke staff can help you stay in compliance. For other industrial and government facilities in California, the LCFS creates an opportunity to generate LCFS credits from biomethane, electric vehicle fueling, electric forklifts, and other types of projects. The sale of LCFS credits is a source of funding for climate-friendly projects such as:

• Industrial or commercial facility electric vehicle fleet fueling projects and electric forklift projects;
• Landfill, waste management, or wastewater treatment plant biomethane projects;
• Refinery and crude oil production facility projects for renewable electricity, natural gas, electrification, or process improvement (energy efficiency); and
• Miscellaneous other projects relating to biomethane and electric vehicle fueling.

Yorke can assist with project feasibility studies, assessment of existing fleet and fueling infrastructure, evaluation of LCFS credit generation potential, preparation of LCFS credit generation initial application and ongoing reports, long-term data management and review, and other related tasks. Yorke can serve as the necessary project management interface between LCFS project vendors and facility staff. This is part of Yorke’s core business, which is serving our clients as technical consultants within their organization.

LCFS Credit Generating Opportunities

Electric Vehicle Fleets and Forklifts

Yorke can assist industrial and commercial facilities in planning and executing new or existing projects for electric vehicle fleets and electric forklifts:

• Fleet planning, including evaluating interaction with other CARB fleet rules;
• On-site electric vehicle charging station feasibility and implementation, if justified;
• Contracts with off-site charging stations, where warranted;
• Assisting with project selection from various options and navigating through bid offerings from multiple contractors; and
• Recordkeeping and reporting for all of the above to fully realize LCFS credit generation revenues.

Yorke can assist clients in understanding the rules, preparing necessary paperwork, managing ongoing data collection, and maximizing LCFS credits obtained. Yorke can serve the client as an “in-house” advisor by managing multiple entities who provide services in these areas but require planning and supervision. This will minimize the burden on in-house staff, and the benefits accrued from ongoing LCFS credit generation are well worth the effort.

Biomethane Production

For landfills, wastewater treatment plants, and agriculture and dairy facilities, Yorke can assist with identifying and planning projects where LCFS credits are generated from biomethane production and delivery to the gas distribution grid. Yorke is currently working with numerous clients in this category on various environmental permitting and compliance projects. Yorke’s certified and experienced LCFS credit verifiers and permitting experts help streamline the permitting process to ensure that new LCFS credit generation projects will be approved more easily. We also provide ongoing LCFS reporting and recordkeeping services to help our clients stay in compliance.

Refineries and Oil & Gas

For the refinery and oil & gas sectors, there are numerous LCFS credit generation opportunities relating to renewable electricity, renewable natural gas, electrification, or process improvement. Yorke has over 20 years of extensive permitting and compliance experience in the refinery and oil & gas sectors in California. We have provided both specialized technical assistance and in-house technical support services and can assist with project identification, selection, documentation, and initial LCFS credit application for these projects. In addition, we can also provide ongoing LCFS reporting and recordkeeping services to help our clients stay in compliance.

LCFS Services

LCFS Data Management Tools

LCFS uses three modules for data management, and Yorke can provide management and support for all three. These tools include:

• The LCFS Reporting Tool (LRT);
• The Credit Banking and Transfer System (CBTS); and
• The Alternative Fuel Portal (AFP).

LCFS Reporting and Pre-Verification

• Prepare plans to manage LCFS reporting, recordkeeping, verification, and oversight to meet regulatory requirements;
• Assist with managing quarterly and annual reporting;
• Assist with opt-in and opt-out for optional facility generating credits;
• Prepare online LCFS reports and assist with submittal assistance; and
• Provide CARB LCFS advance verification support (when verification is not performed by Yorke).

CARB LCFS Emissions Report Verification

• Verification of General LCFS, Fuel Pathways, Petroleum-Based Fuel Reports, and Alternative Fuel Transactions;
• Evaluation of Conflict of Interest;
• Verification planning meetings;
• CARB compliance analysis;
• Development of Verification and Sampling Plans and Verification Report; and
• Submittal of Verification Statement.