On April 4^th, California Air Resources Board (CARB) published the latest revisions to the proposed amendments to the Low Carbon Fuel Standard (LCFS). These changes are required after the Office of Administrative Law (OAL) rejected the latest submission from CARB of the updated regulation.

Timeline and Process

CARB was required to revise the language in the proposed LCFS amendments due to a lack of clarity on how certain updates would be implemented. The revisions were published on April 4th, 2021, well ahead of the deadline, demonstrating CARB’s commitment to completing the amendment process efficiently. Public comments on the proposed changes are due by April 21^st

Once public comments are received, CARB will prepare a response and submit the revised amendments to the Office of Administrative Law (OAL) for consideration. The OAL has 30 days to review and either adopt or reject the amendments, focusing solely on the technical clarity of the language, not the issues or political viewpoints regarding the LCFS

CARB has not yet made a statement on when the proposed changes, specifically the amended Carbon Intensity (CI) targets, will go into effect. If the OAL approves the amendments, the new CI score could be applied to 2025 credits and deficits.

Key Changes in the Updated Proposed Amendments

1. OEMs and Base Credits: CARB has removed the proposal for the Executive Officer to direct a portion of base credits to Original Equipment Manufacturers (OEMs) following a specified regulatory trigger. Instead, base credits will be allocated to Electrical Distribution Utilities (EDUs), with a portion of these credit proceeds allocated to a Clean Fuel Reward to increase grants for Medium-Duty Vehicles (MDVs) and Heavy-Duty Vehicles (HDVs)
2. EV Usage Metering: The metering of electric vehicle (EV) usage must meet 5% accuracy and show that calibration specifications are being followed. If there are no calibration specs from the manufacturer, the credit generator must develop reasonable methods for proving accuracy in their monitoring plan, which will be used by the third-party verifier during the verification process. This requirement affects all EV chargers and forklift meters, with verification requirements for electricity starting in 2026
3. Hydrogen Refueling Infrastructure: Several beneficial revisions have been made to the hydrogen refueling infrastructure crediting, including removing a cost cap and changing the formula for calculating infrastructure credits

Additional Details

Metering for Forklifts: No change in the latest update. California will require metering for all material handling equipment, including forklifts, starting on January 1st, 2026. This requirement ensures that actual energy usage is accurately measured and reported.

Verification Requirements: No change in the latest update. Verification of metering accuracy will be required for all EV chargers and forklift meters. This involves third-party verification to ensure compliance with the specified accuracy standard.

Change to Credit Ownership for Transport Refrigeration Units (eTRUs): No change in the latest update. The right to generate credits for charging eTRUs has changed so that the owner of the facility where the eTRU charger is located can claim the credits.

Multi-Family Rules for EV Chargers: No change in the latest update. Commercial EV Charger owners at multi-family housing units will now be able to claim credits for their charging. For the owner of the EV Charger to claim the LCFS credits, the EV chargers at the multi-family residence cannot be limited to serving dedicated or reserved parking spaces.

Useful Links

• Rulemaking website
• Notice of most recent revision and summary of modifications:  

Please feel free to reach out to SRECTrade with any questions you have on the updates to the LCFS.