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Substitute Pathways and Default Blend Levels for LCFS Reporting for Specific Fuel Transaction Types

This page last reviewed October 2, 2019


The California Air Resources Board’s (CARB) Low Carbon Fuel Standard regulation, which appears at sections 95480 to 95503 of title 17, California Code of Regulations, is designed to reduce greenhouse gas emissions associated with the life cycle of transportation fuels used in California.  CARB staff has prepared this guidance information to describe the regulatory requirements in a user-friendly format.  Unlike the regulation itself, information on this webpage does not have the force of law.  It is not intended to and cannot establish new mandatory requirements beyond those that are already in the LCFS Regulation, nor can it supplant, replace or amend any of the legal requirements of the regulation.  Conversely, any omission or truncation of regulatory requirements does not relieve entities of their legal obligation to fully comply with all requirements of the regulation.


BACKGROUND

This webpage provides the substitute pathways and default fuel blend levels for reporting quantities of fuel when the actual CI or blend levels are not known.

SUBSTITUTE PATHWAYS

Pursuant to section 95488.9(d) of the Low Carbon Fuels Standard (LCFS) regulation,1 CI values for substitute pathways are calculated based on the volume-weighted average CI for that fuel in the prior data year. 

Substitute pathways can only be used for reporting the following transactions types in the LCFS Reporting Tool and Credit Banking and Transfer System (LRT-CBTS):
  • Sold without obligation,
  • Purchased without obligation,
  • Export,
  • Loss of inventory, or
  • Not used for transportation.

When using a substitute pathway, the fuel reporting entity must use the default Company ID and Facility ID values for reporting in the LRT-CBTS, as provided below:

Default Company ID: 0000 (Alt. Fuel Production Facility – Defaults)
Default Facility ID: 00004 (Production Facility Unknown – CI Unknown)

Substitute Pathways for Reporting Fuels With Unknown CI for 20192


Fuel FPC CI (gCO2e/MJ)
Ethanol ETH000S00002019 70.06
Biodiesel BIO000S00002019 34.34
Renewable Diesel RND000S00002019 30.40


Substitute Pathways for Reporting Fuels With Unknown CI for 20203


Fuel FPC CI (gCO2e/MJ)
Ethanol ETH000S00002020 68.57
Biodiesel BIO999S00002020 30.87
Renewable Diesel RND999S00002020 32.23


USING DEFAULT FUEL BLEND LEVELS FOR REPORTING

When fuel blend levels are not known or cannot be reasonably estimated based on the information available to the reporting entity,4  the following default blend percentages must be used to break out and report fuel with relevant fuel pathway code. These default blend percentages apply for reporting only the following transaction types in the LRT-CBTS when blend levels are not known:
  • Export,
  • Loss of inventory, or
  • Not used for transportation.

Please see the example below on how to use default blend percentages for reporting.

Default Blend Percentages for Reporting Fuels with Unknown Blend Levels for 2019


Fuel Blend Default Blend Percentage by Volume
California Reformulated Gasoline with unknown blend level of denatured ethanol 90% CARBOB
10% Ethanol
Fuel labeled as E85 17.45% CARBOB
82.55% Ethanol5 
California Diesel fuel with unknown blend level and labeled as “20% Biomass-Based Diesel Blend” by FTC 20% Renewable Diesel
80% ULSD
California Diesel fuel with unknown blend level and labeled as “B20 Biodiesel Blend” by FTC 12.20% Biodiesel
87.80% ULSD6
California Diesel fuel with unknown blend level of biofuel and with no FTC labeling identifying the blend level For Q1 and Q2 2019 For Q3 and Q4 2019 7

100% ULSD
(when exported via pipeline transport or marine vessel)

97.56% ULSD
2.44% Renewable Diesel
(when exported via pipeline transport or marine vessel)

100% ULSD

(when exported via other transport)

92.86% ULSD
2.44% Renewable Diesel
4.70% Biodiesel6

(when exported via other transport)


Default Blend Percentages for Reporting Fuels with Unknown Blend Levels for 2020


Fuel Blend Default Blend Percentage by Volume
California Reformulated Gasoline with unknown blend level of denatured ethanol 90% CARBOB
10% Ethanol
Fuel labeled as E85 17.21% CARBOB
82.79% Ethanol8 
California Diesel fuel with unknown blend level and labeled as “20% Biomass-Based Diesel Blend” by FTC 20% Renewable Diesel
80% ULSD
California Diesel fuel with unknown blend level and labeled as “B20 Biodiesel Blend” by FTC 13.40% Biodiesel
86.60% ULSD9
California Diesel fuel with unknown blend level of biofuel and with no FTC labeling identifying the blend level

97.4% ULSD
2.6% Renewable Diesel
(when exported via pipeline transport or marine vessel)

92.6% ULSD
2.6% Renewable Diesel
4.80% Biodiesel9

(when exported via other transport)


The default blend percentage value for ethanol in E85 is based on the weighted average ethanol content reported under E85 test program exemption. Default blend percentage values for gasoline and diesel blends containing ethanol and renewable diesel, respectively, are based on the best conservative representation of LCFS data.  Default blend percentages for biodiesel blends are based on the data reported in the Alternative Diesel Fuel (ADF) Program, calculated as a volume-weighted average. 

CARB plans to post annual updates to these values by October for the subsequent reporting year (e.g., update for 2020 reporting to be posted by October 2019).

REPORTING FUEL EXPORT

Pursuant to section 95491(d)(1)(D) of the LCFS regulation, if fuel reported in the LRT-CBTS is subsequently exported out of California, the export must be reported in the LRT-CBTS by the entity responsible for reporting export as described in section 95483(a)(4).10

Blend Level Disclosure and Product Transfer Document (PTD) Requirements 

An entity transferring ownership of fuel is the “transferor” and an entity acquiring ownership of fuel is the “recipient.”  The transferor must provide the fuel blend levels to the recipient that are known to the transferor or reasonably estimated based on the information available to the transferor.  For each blend component of the fuel, the transferor must provide the recipient information pursuant to section 95491.1(b) of the LCFS regulation.

The reporting entity must rely on the information provided via PTD to account for the fuel blend levels for LCFS reporting.  If the blend levels are not known or cannot be reasonably estimated by the transferor, then the PTD must clearly state so.


EXAMPLE

A marketer “ABC Fuels Corp.” purchases 20,000 gallons of unlabeled ULSD below-the-rack, without a LCFS obligation, and ends up diverting 10,000 gallons of that product to a retail station in Arizona via truck during July 2019. What must be reported in the LCFS in this case?

In the Q3 2019 report, ABC Fuels Corp. must report a purchase without an obligation of the 20,000 gallons of ULSD from the upstream entity which passed along the title of the fuel.

In this case ABC Fuels Corp. is the entity responsible for reporting the export pursuant to section 95483(a)(4)(C).10 Therefore, in the same report, ABC Fuels Corp. must report the 10,000 gallons of the product they trucked to Arizona as an export transaction. 

Because the ULSD exported was unlabeled, ABC Fuels Corp. must use the default blend levels provided in the table above for Q3 2019 and relevant substitute pathways for applicable volume of the fuel portion. The following volumes would be reported using the "Export" transaction types:

Breakdown Description Volume to be Reported Applicable Fuel Pathway Code Transaction Type
92.86% of total volume to be reported as ULSD 9,286 gallons ULS000L00072019
(CI = 100.45 gCO2e/MJ)
Export
2.44% of total volume to be reported as Renewable Diesel 244 gallons RND000S00002019
(CI = 30.40 gCO2e/MJ)
Export
4.70% of total volume to be reported as Biodiesel 470 gallons BIO000S00002019
(CI = 34.34 gCO2e/MJ)
Export
Total volume of unlabeled product exported 10,000 gallons


1 All citations to the LCFS Regulation are found in Title 17, California Code of Regulations (CCR), sections 95480-95503.
2 2017 data was used to calculate 2019 substitute pathway CI values.
3
2018 data was used to calculate 2020 substitute pathway CI values.
4 Contact staff for questions related to estimating blend levels. 
5 Based on the data reported under E85 test program exemption (TPE) for 2017.
6 Calculated based on 2017 ADF data.
7 To reasonably accommodate notification considerations and allow sufficient time for fuel reporting entities to update their contractual arrangements as may be necessary pursuant to section 95491(d)(1)(D) reporting requirements, these default average blend percentage values based on prior year values shall be used for Q3 and Q4 2019 reporting.
8 Based on the data reported under E85 test program exemption (TPE) for 2018.
9 Calculated based on 2018 ADF data.

10  "Designation of a Fuel Exporter.  Entities responsible for reporting exports of fuel that has been previously reported in the LRT-CBTS are identified below: 
(A)    When the fuel is sold or delivered above the rack for export, the entity holding title to the fuel as it crosses the California border on its way toward the first point of sale/delivery is responsible for reporting the export in the LRT-CBTS.
(B)    When the fuel is sold across the rack for export, the entity holding title to the fuel as the fuel crosses the rack is responsible for reporting the export in the LRT-CBTS.
(C)    When the fuel is diverted out-of-state below the rack, the entity holding title to the fuel, as it crosses the California border, is responsible for reporting the export in the LRT-CBTS.
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