10 Questions To Ask Your Low Carbon Fuel Standard (LCFS) Provider

1.What are the commission rates and how are they structured?

 

Program participation should come at no upfront cost to you and you should always know the commission and fee structure you’ve contracted for. The total returned value will vary depending on your energy consumption and the LCFS credit market, so commissions should be within reason for the services rendered and should be based on a percentage of the total value created, not on a per-unit (i.e. a per-charger or per-forklift) basis.

e-Mission Control’s industry-leading cost structure is transparent, effective, and most importantly, driven with your interests in mind. Made easier with our software-based automated systems, we strive to take the headache out of a burdensome process and pass the savings on to you.

 

2. What company data is being collected and used to report to CARB?

 

Real-time metered data is required for all equipment types other than electric forklifts. Electric forklift fleets are permitted to use a CARB-approved calculation method that requires lift-, charger-, and battery-specific data points including voltage, AH capacity, model year, charger efficiency ratings, average depth of discharge, etc. as well as facility operational information on charge cycles and shifts per day. This information must be reviewed, at minimum, quarterly.

Our free customer portal, My-eMC, was developed in an effort to continue building on our core mission of adding significant value and transparency to the LCFS program for our partners and make it easier for you to access relevant information such as your eMC Quarterly Incentive Summaries and payment volumes, contracts, facility registrations and approval statuses, current fleet assets, and a host of other helpful guidance. We use this system to update fleet and operations assets in real-time, so as to maximize your credit generation capabilities.

 

3. How frequently is fleet and operation data requested and re-evaluated?

 

Proper accounting for seasonality adjustments (or operations-influencing factors like COVID-19) is paramount in ensuring credit generation accuracy as well as ensuring that you are leveraging the true potential of all equipment on site.

eMC’s turnkey approach to LCFS participation and smooth onboarding process ensures we collect all relevant information to maximize your credit generation and earning potential. Our SaaS tools and expert team make regular check-ins and data confirmations a breeze to ensure what is reported to CARB is accurate.

 

4. Are credits optimized with Renewable Energy Certificates (REC’s)?

 

The use of a zero-carbon electricity source for fleet charging by way of purchasing and retiring REC’s (i.e. book-and-claim) results in significant additional credit generation. At current REC prices, buying and retiring REC’s is a great way to both increase your net profits (the cost of RECs are outweighed by the additional resulting credit generation) as well as support green initiatives within your company.

eMC has zero-CI pathways approved with CARB, a required prerequisite to be able to leverage the financial benefits of REC retirement, and we manage a zero-CI pathway for all of our partners, resulting in optimized credit generation.

 

5. How are you including other public funding programs or mechanisms?

 

While significant, the LCFS program is only a piece of the puzzle when moving toward a zero-emission fleet profile. Infrastructure plays a major role in total cost of ownership calculations, as does the deployment of newer zero-emission technologies found in LCFS-qualified equipment such as eTRU’s, cargo handling equipment, drayage trucks, and on-road light and heavy-duty vehicles.

In addition to the LCFS program, eMC has substantial experience in leveraging CEC, ARB, and AQMD funding programs, utility infrastructure programs and rebates (SCE Charge Ready Transport, PG&E EV Fleet, etc.), as well being well-versed in CORE and HVIP among others. A variety of these may be highly-applicable to your interests and should be an integral part of any zero-emission deployment.

 

6. What software and tools are offered to track and manage fleet and operational data?

 

Transparency is key both in the administration of a comprehensive LCFS program, as well as in any efficient fleet operation. Fleets housed across multiple warehouses present unique challenges, and without proper tools such as software to consolidate equipment data, there is an increased chance of missing crucial CARB reporting deadlines and accuracy requirements.

e-Mission Control (eMC) provides a complete SaaS solution via each partner’s My-eMC portal. There, users can access fleet and incentive payment data broken out by registered facility, view quarterly energy consumption, and gain insight into equipment specs on a per unit basis. Use of this tool comes free of charge to all eMC partners.

 

7. Have the “designee” and “designator” roles, responsibilities, and liabilities been clearly defined and communicated?

 

If you work with a third party to help facilitate your LCFS participation, you will likely enter a “designator/designee” relationship, as defined by the state. This means all quarterly and annual reporting, as well as any obligation to correctly calculate energy consumption will fall on the third party. Having confidence in their ability to properly onboard, analyze, track, and regularly update information about your fleet and operations is of greatest importance.

By intent, eMC contracts and makes clear that we are the legally responsible entity for supplying accurate information on your behalf. We feel strongly about our tools and systems to help ensure data and calculation accuracy, and we make this information available to you in real-time on your My-eMC portal.

 

8. Are credit payment windows within reason?

 

Credits are issued from the state within one week after the close of the following quarter. Adept market participants should be able to transact and return payments for these credits within 30 days.

Realizing that a fleet operator’s ability to quickly reinvest their LCFS proceeds into ‘greening’ their business lies at the heart of CARB’s intent for the program. e-Mission Control is committed to timely remittance of funds. We ramp up communication with partners at the close of the reporting period to keep them looped in every step of the way. Additionally, we provide itemized Incentive Payment Summaries to answer accounting questions, and provide better insight into credit generation, REC costs, and net incentive payout.

 

9. Does the potential vendor refer to the Low Carbon Fuel Standard by name during the negotiation process?

 

The LCFS is a well-established program administered by the California Air Resources Board, and has been used by other states to blueprint their own clean-fuels incentive schemes. Despite its history and popularity, it is still a common practice for vendors to rebrand the program under their own name and distort some of its key monetary benefits for their personal gain. When discussing a partnership, make sure any potential vendor calls the program by its official name and can give directions to state-authored information as questions arise. Any attempt to rebrand the program should be a red flag about the credibility of the entity and its negotiation tactics.

Our goal at e-Mission Control is to demystify the LCFS as much as possible. We will never provide information or advice we can’t back up with sources vetted by the state. From sending out regulatory updates, to explaining the credit reporting and sale process, we want fleet operators to know they can opt for as much interaction in their program as desired. That way, our partners know they’re getting an authentic LCFS experience!

 

10. Where is your business located?

 

e-Mission Control is located at 8th and K in the heart of downtown Sacramento and across the street from the California Air Resources Board.

We are one of the most active stakeholders in the LCFS regulatory proceedings and have exceptional working relationships with the staff and management of the LCFS program. Working with e-Mission Control means you’ll have a seat at the table at all future workshops and working groups that may influence your credit generation capabilities.

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