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Low Carbon Fuel Standard (LCFS) Services

Merjent is a champion for renewable fuel producers. Our staff have been helping producers understand the regulatory requirements of state and provincial low carbon fuel standards. Our engineers have years of renewable fuel consulting experience and we are putting that experience to work helping producers to register and report within these LCFS. These programs are evolving rapidly. Merjent is here to help.

Merjent offers many services under these LCFS.

CARB-ACCREDITED LEAD VERIFIERS

California’s Office of Administrative Law (OAL) approved a Final Regulation Order on January 4, 2019 that made several changes to the California LCFS. These changes included, but was not limited to, addition of a requirement for registrants within the LCFS to obtain third-party validation of applications for new pathways. Beginning in 2019, new pathway applications would need to be completed using the latest carbon intensity model (CA-GREET3.0) and any application not approved by the California Air Resources Board (CARB) by December 31, 2019 would need to the validated by a CARB-Accredited verification body prior to approval by CARB. The rule also required pathway holders with outdated registrations (i.e., pathways based on CA-GREET2.0) to register for a new pathway under latest version of the LCFS using CA-GREET3.0. CA GREET2.0 fuel pathways may not be used for reporting fuel transactions after December 31, 2020. The latest LCFS regulation also requires verification of annual fuel pathway reports starting with the 2020 reporting year (these reports are due March 31, 2021). Merjent has engineers accredited by the CARB as lead verifiers under the California LCFS program. Merjent is actively performing verification services with our verification body partner for various renewable fuel producers across the United States.

LCFS APPLICATIONS

Merjent assists renewable fuel producers to complete their LCFS pathway application and generate the necessary documentation (e.g., compliance monitoring plans). Merjent also helps producers through the online submittal process and (as applicable) the third-party validation process. The third-party validation process involves an audit-like review of the application materials and a site visit by the verification/audit team. Merjent is here to help answer questions throughout the validation process.

Merjent staff also use their first-hand experience with the production process technologies to help guide producers through the regulatory requirements and best address them without creating new, unnecessary burden on the producer.

LCFS DOCUMENTATION

Producers must maintain specific documentation as a part of their LCFS pathways. Merjent staff help to review the existing documentation and implement means of tracking the necessary process information for these programs.

REGULATORY GUIDANCE

We often consult with our clients on the regulatory requirements of these LCFS programs. With so many programs, each operating under different rules, it can be difficult to keep them all straight. Whether you are wondering about ways to lower your carbon intensity, whether a facility modification will qualify for a provisional pathway, or other course-of-business situations, our engineers can help guide you through the regulations.

Contacts

Paul Mordorski
Air Quality Services

paul.mordorski@merjent.com