New mandatory LCFS verification and validation program required beginning January 1, 2020 for the California Low Carbon Fuels Standard.
The California Air Resources Board (CARB) finalized amendments to the Low Carbon Fuels Standard (LCFS) which became effective January 1, 2019. One major change in these amendments is the requirement to complete a third party LCFS validation of fuel pathway applications as well as a third party LCFS verification of ongoing reporting of carbon intensity calculations and documentation. Christianson recently received accreditation as an LCFS verification body to perform these engagements which are a natural connection to our compliance suite of services.
As we enter into the beginning stages of these services, please check out and sign up for our LCFS Implementation Email Series. We are providing FREE status updates and relevant facts surrounding the verification and validation process as we begin these new services.
Many stakeholders have common questions on the new LCFS regulations that we have answered on our FAQ page. If you have a question that is not listed in the FAQ, please submit it at the bottom of the FAQ page and we will address it.
Beginning January 1, 2020, as part of a pathway submission to obtain a certified carbon intensity (CI) score to ship into California, the pathway registrants will be required to complete a validation (audit) of the CI data. The pathway validation will replace the current requirement to submit 2 years of supporting documentation to CARB. All current GREET 2.0 pathway holders will be required to re-register under the new GREET 3.0 model by December 31, 2020. Contact us today to discuss the process and pricing for these engagements.
Also written into the LCFS amendments will be a requirement of pathway holders to track the previous two years of CI data and submit this information in an annual report to CARB. Upon completion of these calculations, the pathway registrant will be required to complete a verification (audit) of the information. These verifications will be due August 31 following the compliance year, with the initial verification due on August 31, 2021. Christianson is offering an option to complete quarterly verifications at no additional cost to you. Contact us today to discuss your options and pricing.
In addition, there are requirements for the First Fuel Reporting Entity to complete a verification of its quarterly fuel transaction reports by August 31, following the compliance year. To discuss if you have verification requirements for your fuel transactions in California, please contact our experts.
The conflict of interest regulations for this new program are very stringent and includes a 5 year lookback of previous services provided, therefore the conversations with your verification body (auditor) need to begin now. Please contact us today to analyze your current relationship with Christianson.
“At REG, we truly appreciate the partnership we’ve developed with Christianson CPAs & Consultants over the years. The team’s approach and response is both professional and top-notch. REG and our audit processes are better off for being partnered with the Christianson team”
– Dave Simon, Director, Compliance Supply Chain Management, REG.