New LCFS amendments push compliance risk into the feedstock supply chain. Are pathway holders and their suppliers ready for it?
by Jeff Baldino
The July 1 amendments to the California LCFS program introduced new feedstock attestation requirements that significantly expand what pathway holders must document, validate, and defend during validation.
At first glance, the changes look like a paperwork update. Pathway holders using specified source feedstocks must now:
- Sign attestation letters tracing feedstock back to the point of origin.
- Maintain documentation for every entity in the supply chain from origin to delivery (points of origin, collectors, aggregators, traders, distributors, storage facilities, transportation method, and mileage).
- Provide attestation letters to CARB verifiers or the Executive Officer upon request.
But these changes aren’t just a paperwork exercise. The feedstock attestation requirements shift the compliance risk from the fuel manufacturing facility into the feedstock supplier network, which is often outside the pathway holder’s direct control.
Many collectors, aggregators, and feedstock suppliers are not owned or operated by the pathway holder. Their documentation practices, internal controls, and recordkeeping systems can vary widely, and they may not be accustomed to operating under LCFS verification levels of scrutiny.
Yet their records now directly influence verification outcomes for pathway holders. And if the records don’t hold up, the consequences aren’t just administrative.
A verifier who cannot substantiate feedstock origin may determine that the associated lifecycle calculations are unverifiable or that the carbon intensity assumptions underlying the pathway are unsupported. In those cases, the issue is no longer documentation—it’s lost LCFS credits.
The challenge is compounded by the fact that CARB has not provided detailed guidance on how verifiers should review the new attestations. For example, one verifier may accept a Used Cooking Oil (UCO) point of origin by confirming a restaurant exists by locating it on google earth. Another may require validating 20% of point-of-origin restaurants and contacting each one to confirm its relationship with the feedstock supplier, quantity of UCO supplied, and supporting records.
These two approaches result in markedly different levels of scrutiny, audit risk, and overhead costs for pathway holders.
Taken together, this means pathway holders can no longer view feedstock attestations as simple signed forms. They increasingly function as a supply-chain compliance system.
At EcoCira, we’ve been working with pathway holders and feedstock suppliers to address these challenges. A few practical steps to consider:
- Confirm that each point of origin exists on a recurring schedule, not just during the initial pathway application process.
- Maintain an up-to-date supplier list and track inactive sources.
- Help smaller suppliers, especially those without strong digital tools, standardize documentation practices.
- Review current feedstock attestations and supporting records annually to identify gaps.
- Build additional time for verification, since added document requirements increase the risk of “unverifiable” findings and credit impacts.
- Prepare suppliers through mock verifications so they understand what documentation may be requested.
Feedstock attestations should be treated as their own compliance system, not merely a signed form. Pathway holders that embrace this shift early will reduce compliance risk, control overhead costs, and avoid the operational disruptions that future verifications are likely to bring.