Five Noteworthy Provisions in the LCFS Amendment

After a more than four-year process, the latest Low Carbon Fuel Standard (LCFS) amendment went into effect on July 1, 2025.

While the amendment process unfolded, the number of credits in the LCFS credit bank soared to over 37 million metric tons (MMT) as of the end of Q4 2024, and the LCFS credit price sharply decreased. The rapid buildup stemmed from a combination of an unexpected volume of renewable diesel credits, as well as credits generated by ultra-negative dairy and swine manure renewable natural gas and electricity pathways.

To prevent a similar situation in the future, the California Air Resources Board (CARB) introduced new structural design elements along with an accelerated decrease in the benchmarks in the compliance curve. The agency also incorporated a big penalty when the carbon intensity (CI) score claimed for certain types of pathways is less than the actual operational CI score. In short, the amendment includes provisions that require careful attention to avoid unintended compliance issues.

Here are five key provisions stakeholders should carefully review.

1. The one-time 9% step-down in the target carbon intensities

To assist in the depletion of the credit bank, CARB included a one-time 9% step-down in the annual CI benchmarks. The step-down resulted in a 22.75% reduction for 2025, compared to what would have otherwise been a 13.75% CI reduction for the year.

2. Automatic (CI Benchmark) Acceleration Mechanism

For the first time, the LCFS includes a built-in mechanism, the automatic acceleration mechanism (AAM) that automatically accelerates annual CI benchmark reductions when the LCFS credit bank is too high relative to deficits. CARB included the AAM in the amendment to address credit and deficit imbalances without the need to go through a lengthy amendment process like the one that just concluded — without it, LCFS credit values could significantly decline again, undermining the purpose of the LCFS.

3. The specified source attestation letter

Each “specified source” feedstock supply chain entity must now maintain a specified source feedstock supplier attestation letter for each feedstock. This applies to all entities in the supply chain, including points of origin, collectors, aggregators, traders, distributors and storage facilities, from point of origin to the fuel producer.

4. The new sustainability provisions

Subject to certain exceptions, pathways that use biomass feedstocks or biomass process energy must now meet defined sustainability requirements. While some provisions took effect on July 1, additional requirements will begin phasing in starting in 2026.

5. An “exceedance” penalty equal to four times the amount of the CI exceedance

The LCFS now adds a steep penalty if the verified CI of a nonprovisional pathway is more than the certified CI for the pathway. In such cases, the penalty is equal to four times the difference between the verified operational fuel pathway CI and the reported CI, multiplied by the volume of fuel reported under that pathway for the applicable year.

How Weaver Can Help

While the above provisions are significant, they’re not the only changes LCFS stakeholders should consider. Weaver’s LCFS team provides a full range of services, from consulting and fuel pathway certification to compliance support and training on both the amendment and the broader LCFS program. Contact us and learn how we can support your compliance strategy.

©2025

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