CARB releases FAQ on new LCFS regulations in advance of deadline

Source: By Susanne Retka Schill, Ethanol Producer Magazine • Posted: Wednesday, January 13, 2016

With a Jan. 31 deadline approaching, the California Air Resources Board released an FAQ to answer frequently asked questions about the changes to the state’s Low Carbon Fuel Standard. CARB has said that those meeting the January deadline will be guaranteed a carbon intensity (CI) rating this year. Ethanol pathways will be processed in the first batch, scheduled to be completed by the end of the first quarter, followed by biodiesel to be completed by the end of the second quarter, and then other fuels. Those missing that deadline will be processed later, and may not get a recertified CI rating before the deadline for all legacy ratings to sunset at the end of 2016.

The 43-page document provides answers to multiple questions regarding the features of the readopted LCFS, such as what documentation will be required to establish the distillers grains yield per gallon of ethanol produced, which is to be calculated on a dry basis, or how emissions from the production of corn oil bound for biodiesel production are to be handled.

Legacy pathways for Method 2A and 2B will be recalculated by the CARB staff, if requested, using the information on file that was used for the calculation of the initial CI value. If a producer doesn’t not agree with the new CI rating, it can apply for a new pathway. Those plants that used Method 1, taking the CI value as listed in the Look-up table, must apply for a new pathway.

There is a reward for ethanol producers in getting the new CI ratings, since CARB has lowered the indirect land use change value from 30 to 19.8 for corn ethanol in the CA-GREET 2.0 model to be used to calculate carbon intensity. Thus, most plants will see a 10 point reduction in their CI.

Several elements of the LCFS have been restructured. First generation biofuel facilities can use a Tier 1 calculator to establish a single CI rating for the typical mix of coproducts, rather than the separate CI ratings for fuel associated with dry, modified or wet distillers grains that was used in the initial LCFS system. The Tier 2 calculator is intended for new fuel pathways and unconventional feedstocks, but can be used by first generation producers realizing significant CI improvements from technologies that can’t be modeled in the Tier 1 calculator.

The FAQ gives some examples of how the Tier 2 calculator is to be used, along with other answers to questions regarding data requirements and other new features of the readopted LCFS.