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Interactions Between the LCFS and VRE Programs in California

New CARB guidance impacts use of Green-e® Energy certified renewable energy for EV charging

Green-e® Participants,

The California Air Resources Board (CARB) recently provided new 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 new 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. 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.

We anticipate this will most heavily impact electric vehicle (EV) operators and their electricity providers that wish to charge vehicles with Green-e® certified renewable energy and receive the California LCFS credit.

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 buy replacement supply (for which LCFS credits are not issued) for EV charging, or no longer seek those LCFS credits.
  • Green-e® participants should inform their customers 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.