First Environment’s greenhouse gas team has successfully completed the first two validations of fuel pathway applications under the California Air Resources Board’s (CARB’s) Low Carbon Fuel Standard (LCFS) program for projects using dairy manure as a feedstock. In May 2020, we completed a validation of the Tier 2 fuel pathway applications for the ABEC Bidart-Old River LLC and Cottonwood Dairy fuel producing facilities in California’s Central Valley. The facilities recently received certification of their carbon intensity (CI) scores from CARB. Both fuel pathways involve the capture of biogas from an anaerobic digester and generation of renewable electricity for use as low carbon intensity transportation fuel in California. Specific details about each fuel pathway (including the application packages) can be found by the clicking the “Current Fuel Pathways” link on CARB’s LCFS website.

About the Low Carbon Fuel Standard

The Low Carbon Fuel Standard (LCFS) is a market-based component of CARB’s regulatory programs implemented in response to the 2006 Global Warming Solutions Act (AB 32). The LCFS is a key part of a comprehensive set of programs to cut greenhouse gas emissions and reduce air pollution in the state by reducing fuel consumption, improving vehicle technology, and increasing transportation mobility options. The LCFS program aims to reduce the carbon intensity of California’s transportation fuel pool by 20% by 2030. It sets annual thresholds for the carbon intensity of transportation fuels used in the state, and any fuel producing facilities with scores above the thresholds are required to compensate with credits. There are three ways to generate LCFS credits:


– Fuel pathway-based crediting

– Project-based crediting

– Zero emissions vehicle infrastructure crediting (e.g., hydrogen refueling, fast charging infrastructure)


This program is designed to increase the range of low-carbon and renewable alternatives, which will reduce petroleum dependency and achieve air quality benefits. Learn more about the LCFS program here.

First Environment’s Verification Expertise

First Environment is a CARB-accredited LCFS validation/verification body qualified to conduct validation of fuel carbon intensity calculations (i.e., “pathway” applications), as well as verification of quarterly and annual fuel reports. With six years of experience providing services to the renewable fuels sector under EPA’s Renewable Fuels Standard (RFS2) program, we are poised to support fuel suppliers with compliance reporting under the LCFS program. In addition, First Environment is CARB-accredited as a verification body for livestock, ozone depleting substances, and mine methane capture projects under the cap and trade compliance offset program. The firm is also a CARB-accredited verification body for GHG emission data reports under the MRR and our team includes transactions, oil and gas, and process emissions sector specialists. First Environment is ANSI-accredited to perform verifications of voluntary offset projects under the CAR, VCS and ACR programs; The Climate Registry member reports; as well as compliance greenhouse gas reporting to Quebec, Ontario, and British Columbia.