Frequently Asked Questions
Commonly Asked Questions About Clean Fuel Programs
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.
There’s no catch. Low-carbon fuel programs are an ingenious and proven successful way to leverage funds from large oil firms and invest in newer, greener technologies, without the need for public funding. These programs are meant to reward upfront investment in electrification, even if part of that investment has already occurred. Continued expansion of low-carbon fuels is the ultimate goal, and over the lifetime of the LCFS/CFP program, it is working.
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.
Seasonality and pausing operations are a common practice with many of our partners. As credit generation is directly correlated to the energy consumed on-site for any particular quarter, eMC will work with your team to make sure we are appropriately accounting for any period of time where electrical energy used as a transportation fuel is not being consumed. We work diligently to make sure the data being reported to the agencies is accurate and representative of your operations.
Nothing. However, if you don’t opt-in your equipment, your utility company will claim your credits on their behalf.
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.
Minimal. Once we have the fleet data completed there’s not much more for you to do with the exception of confirming your fleet data with the eMC team from quarter to quarter to ensure accurate reporting.
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.
Yes! We believe that clean transportation should be available and affordable to all and we have developed tools and systems to facilitate participation by anyone. We are happy to work with businesses of any size and are proud of the fact that only one piece of equipment is all we need to create a great partnership and a new regular revenue stream.
e-Mission Control’s mission is to ensure that programs like the LCFS are accessible and affordable to all businesses. We are always happy to provide a free blind estimate with data you’re currently providing to ensure you’re maximizing the value of the program. We rely heavily on education and transparency to make sure that low-carbon fuel programs are healthy and continue expanding across the continent.
e-MC uses a technology-forward SaaS approach to ensure accuracy and efficiency for all of our partners. In addition to being located in Sacramento and involved in all manner of regulatory proceedings, we have significant public-funding experience, whether through the CEC, CARB, local air district, local utility or many others.
Deciding to electrify is a big choice with a lot of moving parts and we’re happy to help educate on existing opportunities outside of the LCFS program.
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 turn-key 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.
The purchase of renewable, zero-emission electricity increases the total quantity of credits generated by 25-35%. There is a net-financial benefit, as the cost of procuring zero-emission electricity (via the Renewable Fuel Standard program) is less than the additional proceeds from extra credit generation. This process is called “Book & Claim” and e-Mission Control handles this all for you, free of charge. There is an added benefit in that the electricity used to charge/run your fleet is now operating with zero-emissions, enabling to be counted against any internal sustainability initiatives, goals, or scoping.
LCFS or CFP credit generation is relative to the quantity of electricity supplied to your fleet. Common equipment types include forklifts and pallet jacks, commercial on-road fleets and chargers, hybrid refrigeration units, municipal fleet vehicles, cargo-handling equipment, shore-power/cold-ironing and more. For all equipment other than forklifts and pallet jacks, direct metering is required and all slave loads need to be accounted for and addressed. See our page on Metering for more information. For forklifts and pallet jacks, electricity consumption can be estimated based on a variety of fleet and business operation variables.
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.
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!
No, you do not need to own the building to participate in the LCFS/CFP. The first-right of refusal for credit generation depends on the specific equipment category, but typically goes toward the operator of the equipment. The intent of the program is to financially incentivize those making procurement decisions to select more environmentally-friendly equipment vs. their ICE counterparts.
Technically a company could enroll themselves in the program, but it may not make financial sense to do so. Administrative overhead may also significantly increase the cost of enrolling. Companies benefit through using eMC because of economies of scale. A larger pool of credits garners a higher credit price, generating more money for the partner.
Yes, the charging of vehicles at the dealership falls within the nonresidential EV charging and qualifies for the generation of credits. If the dealership has smart chargers with metering capabilities, then this will facilitate the process to do so.
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.
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.
The charge return factor is the ratio of energy supplied to the battery to energy delivered by the battery. Because we want to account for the total kWh attributable to the movement of goods, compensating for the charge return factor is an important consideration in energy consumption estimates.
FSE stands for “Fuel Supply Equipment” which is how agencies track data submission across equipment categories. For on-road vehicle equipment categories, the FSE is the individual vehicle charger. For other categories, such as eCHE, eMHE, and eTRU’s, the FSE can be defined as the facility or location where charging occurs. Data is submitted on a per-FSE basis.
For initial estimates: With few exceptions, we can use whatever information you have on hand along with duty cycle assumptions, industry standards, and current market data to provide an estimate of incentive value. No need to make a concerted effort to collect data beyond what is already currently available.
For actual registration and participation: Ultimately, e-Mission Control will need a variety of variables for registration and reporting including serial number, battery capacities, voltages, model years, and some information on typical shift operation profiles. If this information is not readily available or difficult to collect, with your approval, e-Mission Control can conduct on-site visits to collect necessary information.
If your refrigeration unit is a hybrid or full battery-electric eTRU, it qualifies for credit generation. This includes both over-the-road and containerized eTRU’s. Since eTRU’s require direct metering, e-Mission Control can help facilitate metering hardware installation if, if applicable.
By definition, a high-efficiency charger will be better in converting input energy to output energy and is directly correlated to the charge return factor. As efficiency increases, charge return factor values decrease, resulting in a negligible difference in energy consumption and credit generation.
Because these programs are currently delineated/administered state-by-state, moving facilities and/or equipment within the same state program jurisdiction will not affect credit generation.
In many equipment categories within the LCFS/CFP, the local utility is defined as the default credit generator if not claimed by the opt-in fleet operator. e-Mission Control believes credits should be awarded to fleet operators and for every kWh we report on your behalf, that amount is reduced from the automatic default amount awarded to the local utility. This helps the agency verify that the credits are going to the fleet (once opted in) and avoids “double dippin.”
The LCFS market is a supply and demand market subject to many influencing factors including: fossil fuel consumption volumes, new biofuel project deployment, regulatory proceedings and outlook, electrical energy consumption and prices, and many others.
The Oregon Clean Fuels Program, while nearly identical to the CA program, has only been established for about half of the time as the LCFS. There is currently less liquidity in this market and therefore less upward pressure on credit prices. However, this is quickly changing as more liquid fuels and more electrification take hold.
In 2020, the average LCFS credit price fluctuate between $180 and $200 ($115 to $130 for CFP credits). This program is very liquid and extremely stable, largely leveraging major liquid bio and renewable fuel markets that are the biggest part of the LCFS/CFP. While the price of credits are always subject to market mechanisms, the future outlook for strong credit pricing remains very good.
Renewable Energy Certificates (RECs) are a market-based instrument that certifies the bearer owns one megawatt-hour (MWh) of electricity generated from a renewable energy resource. Once the power provider has fed the energy into the grid, the associated REC can then be sold on the open market as an energy commodity for use by a variety of end consumers, including fleets.
By procuring and “retiring” REC’s (and therefore zero-emission electricity) the quantity of credits generated by any particular LCFS/CFP participant increases, resulting in a net-positive financial return. There is an added benefit in that the fleet in which REC retirement occurs is utilizing zero-emission electricity, available to be accounted for in sustainability goals, marketing, etc.
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.
The LCFS/CFP operates as an open market, where credit generators contract and sell credits directly to regulated entities like oil producers, importers, and blenders. Funds to support electrification efforts come directly from these entities to eMC and are distributed to our partners. These are NOT public funds/tax dollars and can be stacked with other publicly-funded incentive programs you may already be receiving.
The LCFS/CFP program helps significantly bring down the operational cost of your equipment over time, indefinitely, as long as you are operating it. Operational costs should be evaluated as part of the Total Cost of Ownership (TCO) model when deciding what new equipment types to invest in.
If there is need for support in additional upfront capital resources, e-Mission Control can help educate you on a variety of potential grant or cost-share programs, including those from local air districts, utilities, public agencies, and more.
e-Mission Control operates entirely on a net-back model, meaning we retain a percentage of the net proceeds from the credit sale without any fees or upfront costs to you. There are no minimum quantities or other service fees.
The purchase of renewable, zero-emission electricity increases the total quantity of credits generated by 25-35%. There is a net-financial benefit, as the cost of procuring zero-emission electricity (via the Renewable Fuel Standard program) is less than the additional proceeds from extra credit generation. This process is called “Book & Claim” and e-Mission Control handles this all for you, free of charge. There is an added benefit in that the electricity used to charge/run your fleet is now operating with zero-emissions, enabling to be counted against any internal sustainability initiatives, goals, or scoping.
Ideally, we would use energy consumption data specific to your operations. However, this is not usually readily available so if needed we can use spec sheets, duty cycle information, and industry standards to back calculate the energy consumption at your facility. That’s all we need to estimate your incentive return for the current reporting quarter.
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.
No, you do not need to own the building to participate in the LCFS/CFP. The first-right of refusal for credit generation depends on the specific equipment category, but typically goes toward the operator of the equipment. The intent of the program is to financially incentivize those making procurement decisions to select more environmentally-friendly equipment vs. their ICE counterparts.
Technically a company could enroll themselves in the program, but it may not make financial sense to do so. Administrative overhead may also significantly increase the cost of enrolling. Companies benefit through using eMC because of economies of scale. A larger pool of credits garners a higher credit price, generating more money for the partner.
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.
Good question and a common misconception. Functionally, the idea of low carbon fuel programs is less about increasing the cost of compliance of regulated parties, and more about providing funds and incentive (paid from the regulated parties, not the state) to bring down the cost of low carbon fuel alternatives so to make it easier on fleet operators/procurement managers to select low-carbon equipment. These programs have proven to be an exceptionally effective means to decrease the carbon intensity of local transportation fuel mixes all over the world.
To clarify, “Residential EV” credits are awarded to the local utility. This is because the state wants to incentive utilities to help facilitate residential charging. Within the “Non-residential” categories, the same applies, however, if the commercial fleet opts in, they are given priority over the local utility. The state wants fleet operators, who make equipment procurement decisions, to be incentivized financially through the LCFS/CFP to continue deploying zero-emission battery-electric equipment.
The WAIRE program is specific to the South Coast Air Quality Management District and not related to LCFS. Funds from other state sources (HVIP & CORE) can NOT be used to buy equipment and buy “WAIRE points,” however, LCFS funds can!
While low carbon fuel programs are only currently active in some geographies (CA, OR, WA, BC), the success and effectiveness of these market-based tools have garnered a lot of attention. Many states in the US are working through legislative processes to adopt their own versions, or in some cases, entirely mirror the programs in CA and OR. Canada federally is implementing a program starting next year, and the development of a federal program here in the US is very likely. Additionally, even if your headquarters are located in another state, you may still be eligible if you have operations within an active state.
Technically speaking, propane vehicles are eligible for credit generation now, however, the intent of the LCFS/CFP program is to reduce the use of the high carbon intensity fossil fuels. Credit generation from propane and/or fossil natural gas is relatively low compared to zero-emission electricity.
All transportation fuels are apart of the program, including gasoline and diesel (deficit generators) as well as low-carbon fuels such as renewable fuels, biofuels, and electricity (credit generators). e-Mission Control works with companies and fleets utilizing electricity as a fuel source as we promote the transportation economy electrifying over the decades to come.
The short answer is no. For liquid fuels, the manufacturer of the fuel typically is the first fuel-reporting entity and credit generator, and as such, manufacturers of E85 receive LCFS credits.
Yes and no. e-Mission Control manages “book and claim” processes for you, which means we will procure zero-emission electricity for your entire fleet whether or not you have solar on site, resulting in a net-positive financial gain (the cost of zero-emission electricity is outweighed by the additional credit generation from the LCFS/CFP program). However, if you have qualified solar assets on site we can help facilitate additional revenue generation from REC creation within your local RPS program.
Good question and a common misconception. Functionally, the idea of low carbon fuel programs is less about increasing the cost of compliance of regulated parties, and more about providing funds and incentive (paid from the regulated parties, not the state) to bring down the cost of low carbon fuel alternatives so to make it easier on fleet operators/procurement managers to select low-carbon equipment. These programs have proven to be an exceptionally effective means to decrease the carbon intensity of local transportation fuel mixes all over the world.
Have other questions about Low Carbon Fuel Standard or Clean Fuel Programs? Please reach out and we are happy to help