In the first quarter of 2021, the Compliance Department at Christianson saw a slew of new validations for the CA Low Carbon Fuel Standard (LCFS) come across our desks. We also heard from many existing LCFS participants who were unsure of their reporting requirements under the new LCFS regulation. Having the right team is crucial to successful compliance. Do you have your LCFS compliance requirements covered? This team roster will ensure you do.
1. Staff – the most successful participants have made LCFS compliance part of their company culture. Training is provided so staff know their respective roles and responsibilities. To manage this, a smart participant will have a manager/CFO to oversee the program and a technical specialist/Controller to manage the information gathering and reporting.
2. Consultant – the LCFS program, lifecycle analysis, and GHG reporting are complex. Successful participants typically engage a consultant to assist with the initial application, writing the Monitoring Plan, populating the CI calculator, and working with CARB to iron out kinks. It is a best practice to retain the consultant to provide advice during the initial validation and subsequent annual verifications. They will help you overcome hiccups during the validation.
3. Verification Body – the LCFS has strict conflict of interest requirements. Except for the first 3 years of the program, the same firm cannot provide both consulting and auditing services to participants. LCFS also requires Verification Body firm rotations every 6 years. To set themselves up for success, smart companies engage a third-party Verification Body right from the start to validate their initial application. This ensures your compliance relationship begins on the right foot and prevents hiccups down the line. And at Christianson this can often provide costs savings by stacking services (like RIN attestations).
4. CARB – when in doubt ask CARB! The staff at CARB are here to help all the players (participants, consultants, and verification bodies) of the LCFS program work together to ensure the accuracy, integrity, and success for the program to achieve its low carbon goals. Don’t be afraid to reach out and ask questions! Begin a relationship from the start with CARB, either directly or through your consultant, and you will not regret it.
Not sure where to begin? Give us a call and we can talk you through your options.
Is your business already participating in the LCFS and not sure what to do next? Now that you have submitted your annual reports to CARB, it is time to pick a Verification Body for the annual verification due Aug. 31, 2021.
