Interactions Between the LCFS and VRE Programs in California (Updated)
CARB guidance impacts use of Green-e® Energy certified renewable energy for EV charging
The California Air Resources Board (CARB) has provided guidance regarding Low Carbon Fuel Standard (LCFS) credits that is incompatible with Green-e® Energy requirements for use of California’s Voluntary Renewable Energy (VRE) program, which retires cap-and-trade allowances on behalf of voluntary purchases of renewable energy. In this guidance, CARB confirms that renewable energy certificates (RECs) used to receive LCFS credits for low carbon intensity (low-CI) electricity cannot also be used for the VRE program. Under Green-e® rules, RECs from California facilities or facilities directly importing electricity into California that are used in a Green-e® Energy certified product must be counted in the VRE program. As a result, renewable energy used to receive LCFS credits cannot also be Green-e® Energy certified, except for certain 100% renewable electricity products that can include renewable energy used for vehicle charging and the LCFS. These products must meet additional criteria and include additional disclosure to customers.
Background
Per CARB’s Guidance on Retiring Allowances from the Voluntary Renewable Electricity Reserve Account (April, 2019), there is “a prohibition on claiming the same RECs for VRE allowance retirement and for the purposes of the Low Carbon Fuel Standard Low-Carbon Intensity Electricity pathway.”
Also per CARB’s Low Carbon Fuel Standard (LCFS) Guidance 19-01, Book-and-Claim Accounting for Low-CI Electricity (April 2019), “RECs or other environmental attributes of the [low-CI] electricity [used] cannot be claimed under any other program with the exception of [...] California’s Cap-and-Trade program (provided that the low-CI electricity is not claimed in the Cap-and-Trade Program’s Voluntary Renewable Electricity (VRE) program [...]).” Green-e® rules require VRE allowance retirement to maintain the GHG-reduction impacts of voluntary renewable energy purchases.
Recommendations
- Green-e® participants that currently receive LCFS credits for EV charging by customers participating in a Green-e® certified program must no longer seek those LCFS credits, buy replacement supply (for which LCFS credits are not issued) for EV charging, or, for 100% renewable energy products only, provide additional disclosure to customers about renewable energy used for vehicle charging and the LCFS per section IV.C1.9 of the Green-e® Energy Code of Conduct. These products must maintain a threshold of at least 25% of the product that is used solely for voluntary purposes, and not LCFS credits or the CA RPS.
- Green-e® participants should inform their customers (e.g. charging stations) intending to use Green-e® Energy Certified products to receive LCFS credits that it is not possible under the current CARB and Green-e® rules. However, additional RECs can be procured to meet Green-e® requirements.
Any updates to this guidance will be published here. If you have any questions, feel free to contact your Green-e® representative.