LCFS Frequently Asked Questions (FAQ)

There are no extensions available for the verification report, all reports are due by August 31 following the compliance year.  If your report is not complete by August 31 then the verifier will file an Adverse Statement with CARB.

If you have an active pathway with a certified CI then you have annual reporting requirements as well as an annual verification requirement.  If you have generated less than 6,000 credits or deficits in a given year then you can defer your verification requirement for up to two years.  At the end of the third year you will need to complete verifications for each of the previous compliance years and submit 3 verification statements.  Deferring a verification eliminates the need for a site visit every year.

If you need to sell to California before you have a provisional or certified CI with CARB, you can apply to CARB for a temporary pathway which will give you a conservative (higher) CI for your fuel.  CARB approves temporary pathways by quarter and will usually let you use a temporary pathway for 2 quarters before requiring your own individual CI.

If you do not need to ship to California right away and can hold off on actually sending fuel, then you can claim CI credits from the start of your application period (the start of your provisional pathway calculator).  There are CI pathway allocation rules that tell you how to allocate fuel to various pathways that you may hold and for every gallon you ship either within or outside of California you must apply it to a pathway.  This tracking will essentially keep an inventory of credits that you may have in inventory.  At the end of each calendar quarter, your credits are constrained by physical fuel inventory.  So you can’t hold more credits in inventory across your pathways that what you have in physical fuel inventory at the end of a quarter.  If you can work this out to keep your lowest CI fuel credits in inventory, then you can begin shipping from those pathways once you have approval for your provisional/certified CI.

A verification is an audit of a company’s quarterly or annual reporting to CARB.  A validation is an audit of a company’s pathway application for a certified CI.

Third party validations are required starting January 1, 2020.  If you submit a pathway application after December 31, 2019 or if you have a pathway application in process that has not been deemed complete by December 31, 2019 then you will need to engage a third party verifier to conduct an audit.  You have 6 months from the submission date of your application to complete a validation.  If you submitted a pathway application in Q4 of this year or plan to submit one in early 2020, you should be contacting verifiers now. Verification work cannot begin until you have filed and attested to the accuracy of your reporting with CARB.  If you choose to do annual verifications, then the initial verification would start end of Q1 or begin of Q2 in 2021.  If you opt in to do quarterly verifications then work could start in Q1 or Q2 of 2020 and you should be setting up a plan with your verifier now.

You should contact any potential verifiers and request that they do a conflict of interest evaluation to ensure they are able to complete your verification or validation.  Christianson has submitted an initial evaluation to CARB to clear a number of our services, there are only a select few that are considered high conflicts.  Please contact our experts for more information.

CARB currently has not addressed how they will handle facility shutdowns.  They have advised plants to contact CARB when a shutdown is expected so that they can evaluate the case and determine how to proceed with the Tier 1 calculators and with verifications.

In order to begin validation procedures we have to submit a conflict of interest evaluation and receive approval from CARB in order to proceed.  The approval from CARB can take up to 60 days.  We have inquired about when the conflict of interest forms will be available to complete and submit for evaluation but have not heard anything earlier than the end of the year.  Please check back here for updates on when conflict of interest forms are available for submission.

As of Feb, 23, 2021 CARB does not have a process for participating entities to submit their LCFS Annual Report for 2020, which are due March 31, 2021. Annual verification work — including site visits and detailed testing — with your Verification Body cannot begin until after the Annual Report has been submitted. We will keep you posted with updates in our monthly Low Carbon Opportunities newsletter and post new information on this FAQ Page website as we get it.