On December 19, the California Air Resources Board (CARB) revealed their long-awaited proposal to update and extend the Low Carbon Fuel Standard (LCFS). Among the most significant changes:
Increases 2030 carbon intensity (CI) targets from 20% to 30%, including a one-time 5% reduction of the CI benchmark in 2025
Extends CI reduction targets to 90% CI by 2045
Creates new auto-acceleration mechanism to help stabilize the credit market in the event of rapid decarbonization that outpaces deficits, beginning in 2028
Phases in some limitations to biomethane crediting
Reduces credits from eForklifts
Adds third-party verification requirement to electricity and other fuels
Expands ZEV infrastructure crediting for medium and heavy-duty charging
Staff published a Preliminary Draft Report, Regulatory Text, and nearly 12 total documents on its rulemaking page. These 500+ pages make for a good read over the holiday break.
What to Watch for Next
The agency indicated a formal regulatory notice will be issued in early January 2024, which kicks off a 45-day public comment period. The proposed regulations can then be adopted at a subsequent board meeting, potentially as early as March 21.
Check back here for more analysis on these proposed changes!
The California Air Resources Board (CARB) published Q2 2023 data for the Low Carbon Fuel Standard (LCFS) today. Consistent with trends dating back to 2021, low carbon fuel producers generated 1.6M more credits than deficits, pushing the cumulative credit bank to over 18M credits.
Source: California Air Resources Board
Record Credit Generation
More credits were generated in Q2 (5.5M) than in any previous quarter of the program, led by increases from the largest credit sources: renewable diesel (14%), renewable natural gas (28%), and electricity (7%). Two key trends underpin the consistent growth in net credits: 54% of diesel sold in CA last quarter came from renewable feedstocks while the average carbon intensity (CI) of renewable natural gas fell to its lowest mark of -131 g/MJ.
There was also a 50% increase in credits from alternative jet fuel (also referred to as sustainable aviation fuel) which still represents less than 1% of all credits. Meanwhile, there were modest declines in credits from ethanol (-11%), propane (-11%), and biodiesel (-5%).
Source: California Air Resources Board
EV Credits Rebound
Credits from EV charging bounced back from a quarterly decline in Q1, driven by increases in both light-duty (12%) and heavy-duty (11%) on-road EV charging. Residential EV charging still made up about half of all EV credits, ahead of forklifts (23%) and on-road EVs (18%). Credits from DC fast-charging infrastructure rose by about 12%. Overall, EVs are the second largest source of credits, representing about one-quarter of all credits in the program.
Source: California Air Resources Board
Credit Prices Hover Above Six-Month Low
LCFS credit prices closed October around $68/credit, up slightly from six-month lows in September following CARB’s publication of a regulatory document which hinted at major program changes including the strengthening of CI targets and limitations on biomethane crediting. CARB is expected to publish its final proposal by December, which triggers a 45-day public comment period before the governing board can approve rule changes.
Due to SRECTrade’s retirement as an Approved Vendor in the Illinois Adjustable Block Program on August 10th, 2022 (see this blog post for more information), extensions will no longer be filed for projects who have not met their interconnection deadlines.
Adjustable Block Program (ABP) projects are awarded a contract after their Part I approval. The project then has 12 or 18 months to provide energization documents and be submitted for Part II approval. In the past, SRECTrade has filed extensions on behalf of projects that required more time. Beginning in November, 2023, any projects that have not been Part II submitted by their deadline will be canceled with SRECTrade. This will result in the forfeit of the application and collateral fees (that are non-refundable once awarded a contract), and will require the project to be resubmitted through a different approved vendor to participate in the ABP program.
SRECTrade will continue to provide services for all applications that are Part II submitted prior to their energization deadline. To help ensure your application is not canceled, please submit any outstanding documents 6 weeks prior to your deadline.
SRECTrade looks forward to continuing service of its Designees and existing clients during the remainder of their participation in the ABP.
The first batch of data for the new Washington Clean Fuels Standard (CFS) has been made available by the Washington State Department of Ecology. So far, Ecology has published:
No credits were transferred in July after technical issues with the Washington Fuel Reporting Systems triggered a one-month delay in the first issuance of credits. However, 27,055 credits were transferred in August. The average price from the four reported trades was $106.66. The price of Washington CFS credits was about midway between those reported in CA ($77) and OR ($137) during the same month. Credits from one program cannot be sold in another.
Q1 2023 Credit and Deficits
Ecology reported 275k credits generated and 227k deficits generated, a net credit build of about 47k credits. Entities with compliance obligations do not have to retire credits until next year, and credits do not expire so they may be held indefinitely by market participants.
The largest source of credits was ethanol (75%), followed by renewable diesel (12.1%), biodiesel (11.8%), and electricity (10.8%). Credits from residential EV charging, which are separately calculated and issued by Ecology, have not yet been issued for Q1 or Q2.
The deadline for reporting fuel consumption for the Q2 2023 reporting period is today. Ecology has not yet set a publication schedule for reporting quarterly credit and deficit data.
Source: Washington Department of Ecology
What’s Next for the Washington CFS?
Ecology will create a zero-emission vehicle infrastructure or “capacity credit” program for public DC fast-charging and hydrogen refueling stations. Stations approved under this program may generate CFS credits based on the fueling capacity of those stations. Guidance on this program is expected to be released before the end of the year.
Ecology must also address the inclusion of alternative jet fuel pathways in the CFS after the passage of SB 5447. A rulemaking may be initiated as soon as this year or early next year.
The timeline for implementing changes to the California Low Carbon Fuel Standard (LCFS) became clearer last week. At an industry conference, California Air Resources Board (CARB) Executive Director Dr. Steven Cliff indicated a final proposal would be made available in the “November timeframe” with hopes of approval by next spring. The announcement came after the September 8 publication of the Standardized Regulatory Impact Assessment (SRIA).
Under this timeline. CARB could implement a mid-year adjustment to the 2024 carbon intensity targets, increasing compliance obligations for fuel suppliers. An even more significant adjustment or “step down” is being considered for the 2025 targets, as indicated in the SRIA. The document evaluated other significant changes to the program, including a target acceleration mechanism, the inclusion of intrastate fossil jet fuel as a regulated fuel, and the phasing out of biomethane and forklift crediting. However, Dr. Cliff reiterated that the SRIA, which precedes any formal rule-changes to be considered by the regulatory body which oversees the LCFS, “is not the final proposal. It’s not even the proposal.”
Source: CARB Standardized Regulatory Impact Assessment for LCFS 2023 Amendments
What To Watch For Next
Regulatory staff will present on changes to the LCFS at the September 28 CARB non-voting meeting. The next formal milestone will be the publication of a Rulemaking Package which starts the 45-day public comment period, after which CARB may adopt new provisions to the LCFS rules.
Source: CARB Staff Presentation at 9/14 EJAC Committee Tweet
The California Air Resources Board (CARB) held a workshop on August 16 to present updates to a model that assesses the feasibility and economic impact of proposed changes to the Low Carbon Fuel Standard (LCFS). Although the workshop did not specifically address policy changes, the inputs of this model are suggestive of what CARB may put forward in formal rule changes coming later this fall.
Why is CARB making changes to the LCFS?
The last time significant changes to the LCFS were made was in 2018. Since then, the agency has workshopped several policy and procedural changes and received significant stakeholder and community feedback. During workshops held last summer, CARB presented a plan to align LCFS with several key climate policies, most notably the 2022 Scoping Plan, which was formally adopted in December 2022.
Key Program Changes
The model inputs included many of the policy changes that have been discussed at public workshops over the past 18 months and may hint at what the agency will propose later this year. Some of these changes are highlighted below:
Accelerating Carbon Intensity Targets
Carbon intensity, a measure of lifecycle emissions of a fuel, is used as a benchmark to compare gasoline, diesel, and other low carbon fuels such as biofuels and electricity. The benchmark decreases each year to meet the current target of 20% reduction from 2010 levels by 2020. As the benchmark decreases, conventional gasoline and diesel generate more deficits (i.e. greater demand for credits) which produces the long-term incentive for lower carbon fuels.
Reduction in CI Benchmark Over Time
CARB has proposed advancing the 2030 target to between 25% and 35% reduction, while adding a 2045 target of 90% reduction. The 2030 acceleration is significant because it would increase the demand for credits in the near term, depending in part on how the targets “step down” from their current levels in order to meet the new 2030 target. Proponents of steeper 2030 targets argue this will provide needed price support for the LCFS credit market which has significantly declined in recent years due largely to an oversupply in credits. Others caution that overly stringent targets would increase fuel prices and could undermine political support for the program.
In the latest iteration of the model, CARB included a 30% reduction target for 2030 with a significant step down between 2024 and 2025. While not an official proposal from CARB, it might indicate what the agency is ready to move forward with in the fall.
CI Adjustment Mechanisms
Source: California Air Resources Board
Phasing Out eForklifts
In previous workshops, CARB has proposed reducing and eventually phasing out credit generation from eForklifts. Staff discussed reducing the credit generation potential of lighter classes of forklifts and requiring electricity consumption to be metered. Forklifts are unique in that CARB allows for electricity consumption to be estimated. However, both the Oregon Clean Fuels Program and the Washington Clean Fuel Standard have recently required metering for electric forklifts in their programs. CARB’s latest model included a significant reduction in credits from forklifts, suggesting these changes are still on the table.
Verification Requirements for ElectricityCredits
In a previous workshop, CARB proposed requiring all participants generating credits from electric vehicles to go through an annual verification process. Electricity is the only major credit source where fuel consumption reporting is not required to be independently verified. Other programs, such as the Canadian Clean Fuel Regulations require verification for all fuel types.
Expanding Infrastructure Crediting to Medium/Heavy-Duty Vehicle Charging
Under the LCFS, some public fast-charging stations are eligible to generate credits based on the total capacity of the site, not solely on electricity consumption. CARB has proposed expanding these provisions to stations that provide charging to multiple medium and heavy-duty fleets. CARB’s latest model included credit generation from this pathway, suggesting that the agency is still considering this change.
What’s Next for LCFS?
During the workshop, staff shared an updated timeline which confirmed that formal changes to LCFS will not be considered for adoption until early 2024. However, the agency expects to move forward with the formal rulemaking process later this fall, and implement the changes “sometime in 2024.”
The California Air Resources Board (CARB) published quarterly program data for the Low Carbon Fuel Standard (LCFS) on June 30, 2023 and announced another workshop for August 16 to discuss changes to the program.
Credit Bank Adds 1.3M Net Credits After Sluggish Q1
The cumulative credit bank, a measure of net credit generation over the lifetime of the program, grew for an eighth consecutive quarter and now stands at 16.5M credits. Deficits were down in Q1 (-3%), driven largely by a decline in gasoline volume (-9%). Credits from all sources (-6%) fell for the first time in 2 years driven in part by reductions in volume from electricity (-5%), biodiesel (-3%), and ethanol (-2%). Average carbon intensities (CI) were up across the major credit sources as well, including RNG (+21%), biodiesel (+8%), RD (+9%), and electricity (+3%). Finally, the more stringent CI targets for 2023 kicked in, which reduces the number of credits per unit of low carbon fuel when compared to 2022.
EV Credits Take a Step Back in Q1
Credits from electricity fell last quarter (-7%) for the first time since the COVID pandemic, driven primarily by a 12% decline in residential EV charging credits which are issued to utilities based on a formula. Credits also decreased across other categories including eForklifts (-1%), ocean-going vessels (-13%) and fixed-guideways (-11%). EVs still remain the second largest source of credits under the LCFS and among the fastest growing fuel type.
What’s Next for CA LCFS?
CARB scheduled a workshop on August 16 to present updates to their model that is used to assess the feasibility and economic impact of proposed changes to the program, including establishing more stringent 2030 CI targets. In the previous workshop held in May, CARB staff had reiterated their intent to initiate a formal rulemaking process to make changes to the LCFS by this summer, with a targeted implementation date of January 1, 2024.
CARB will release Q2 2023 program data by October 31, 2023.
The California Air Resources Board (CARB) published quarterly program data for the Low Carbon Fuel Standard (LCFS) on April 28, 2023. In this piece, we will provide some analysis of the new data and highlight interesting trends.
Credit Bank Growth Slows
The cumulative credit bank, a measure of net credit generation over the lifetime of the program, grew for a seventh consecutive quarter to reach a new program high of about 15M MT. However, quarter-over-quarter credit growth slowed to 2% while deficits rose by 5%, resulting in a net build of 1.65M MT, slightly lower than last quarter’s build of 1.76M MT and halting a three-quarter trend of growing credit builds.
Source: CARB
Q4 2022 Credit Trends
Renewable diesel (RD) rebounded from a rare quarterly decline in Q3, growing by 7% to a new program high of 2.5M MT. RD remains the largest source of credits under the program at 36%.
Renewable natural gas (RNG) volumes dropped by about 2% but remains the lowest average carbon intensity (CI) fuel at -119 gCO2e/MJ. Notably, a bill was introduced that would direct CARB to restrict dairy digesters from generating credits under the California program.
Credits from ethanol declined by 5%, while credits from biodiesel and hydrogen both dropped by 4%.
Source: CARB
EV Credit Growth Also Slows
Credits from electric vehicles represented one-quarter of all credits under the program but grew by only 66k MT last quarter, the least since Q4 2021. The distribution of credits across the categories of eligible EVs remains unchanged: residential (49%), eForklifts (23%), and non-residential light/medium-duty (15%). Notably, credits from heavy-duty EVs grew by 10% while credits from electric cargo handling equipment and electric refrigeration units both fell by about 5%.
Throughout 2022, the three major US cell phone carriers began to retire their 3G radio bands. Many sites in the SRECTrade aggregate utilized a 3G connection to report monthly kWh production data and were unable to auto-report.
SRECTrade collaborated with Enphase Energy’s 365 Pronto Platform to provide our clients with a solution to replace their existing 3G meter with a new meter, allowing them to auto-report once again. Clients were able to purchase new meters through the 365 Pronto Platform from Fall 2021 through November 9, 2022. As of February 15, 2023, a majority of affected sites have had their meters replaced and have resumed reporting to the Massachusetts Clean Energy Center’s Production Tracking System (MA PTS).
Moving forward, clients need to ensure their site continues to report by monitoring their MA PTS accounts and checking for email communications from SRECTrade regarding their site’s data connection to MA PTS. Any inquiries regarding system performance/diagnostics need to be addressed by your system installer or another installer familiar with the on-site equipment (MA PTS installers).
FAQs:
My site resumed reporting but not all production was captured while I was offline. What happens now?
A: Unfortunately, it is possible that your system’s production will not be recovered before your new meter installation is reflected in your SRECTrade account. Unless there was another issue present with your system during mid-late 2022, you will only receive SRECs for your production that was reported successfully after your meter swap was completed.
Why has my meter swap not been completed after purchasing a meter and installation service through the 365 Pronto Platform?
A: The 365 Pronto Platform team has confirmed that multiple sites still have ongoing installs.
I was cc’d on an email to PTS regarding the meter swap. Why was I included?
A: SRECTrade has been sending meter swap notifications to MA PTS to have sites that had a recent swap be able to capture any data from between the old meter going offline and the new meter going online on the day of the swap. MA PTS prefers to have site owners included in email communications regarding their on-site meter.
I purchased a new meter and installation service through the 365 Pronto Platform, but my site has still not resumed reporting to MA PTS. What are the next steps?
A: If you have completed a meter swap but noticed no production reflected in MA PTS or have not been included on a meter swap email, then your meter or system is likely offline and needs troubleshooting. We recommend you check with your system’s original installer or check the list of approved installers from MA PTS to troubleshoot your system and have it resume production to MA PTS.
My utility bill is larger than expected. What do you recommend?
A: Most of the systems that completed a meter swap were installed 5-10 years ago. A majority of systems are built on historical usage from past utility bills and now in 2023, your energy needs may have changed. We recommend you check with your system installer to be sure your existing system still fits your energy needs.
Still have questions?
You can contact SRECTrade at (415) 763-7732 or send us an email.
SRECTrade has changed our policy regarding the distribution of IL ABP Change of Ownership paperwork. Effective immediately, SRECTrade will be the sole distributor of all IL ABP Change of Ownership paperwork (excluding the Voided Check, Settlement Statements, Divorce Decrees, Death Certificates, and/or Deeds) to clients via RightSignature.
As a result, Designees and other third parties are no longer permitted to distribute IL ABP Change of Ownership paperwork to clients. If you are notified of a home sale, please notify us so we can provide the paperwork to the respective parties once we have all necessary contact information from the buyer.
By implementing this change, we aim to reduce the confusion around the IL ABP Change of Ownership process and ensure clients have the correct paperwork. As you may be aware, GATS periodically releases new IL ABP Change of Ownership forms, and it is crucial that clients receive the most up-to-date paperwork.
We appreciate your cooperation in adhering to this new policy. If you have any questions or concerns, please do not hesitate to contact us.
