Low Carbon Fuel Standard (LCFS) Demonstration of Physical Pathway Form

ARB approval of the facility’s Physical Pathway Demonstration is needed for a Complete Fuel Producer Registration.

A regulated party can generate LCFS credits for its fuel or blendstock only if there is an ARB-approved physical pathway demonstration for the fuel (see section 95484(c)(2) of the LCFS regulation). Fuels with a pending physical pathway demonstration approval are to be reported using physical pathway code PHY10 in the LCFS Reporting Tool (LRT).

A “physical pathway” is the applicable combination of actual fuel delivery methods (e.g. trucking routes, rail lines, pipelines, and any other fuel distribution methods) through which the regulated party reasonably expects the fuel to be transported under contract from the entity that producedor generated the fuel, to any intermediate entities, and ending at the fuel blender producer, importer, or provider in California.

A physical pathway demonstration must meet the following three requirements:

1. Initial Demonstration of Delivery Methods (see section 95484(c)(2)(A) of the regulation).

2. Initial Demonstration of Fuel Introduced into the Physical Pathway (see section 95484(c)(2)(B) of the regulation).

3. Initial Demonstration of Fuel Removed From the Physical Pathway (see section 95484(c)(2)(C) of the regulation).

The documentation must include:

  1. Narrative description the route forthe fuel from the production facility to California. The narrative description should include identification of each company that owns and/or has physical custody of the fuel at each segment of the physical pathway and should be consistent withthe Physical Pathway Demonstration Table(below).
  1. A map(s) that shows the combination of truck/rail lines or routes, interconnected pipelines, and other delivery methods (each of which can be considered a “segment”) that, together, comprise the physical pathway from the production facility to California. Please clearly identify the starting, ending, and other transfer points along the route. You may consider using Google Maps or similar. If more than one company is involved in the delivery, each segment on the map must be linked to a specific company that is expected to transport the fuel through each segment of the physical pathway.
  1. For each segment of the physical pathway identified on the map(s), thecorrespondingpathway and associated company information should be clearly identified in the Physical Pathway Demonstration Table (below).
  1. Product transfer document(s) to show transfer of ownership and/or custody,transport, and delivery of the fuel toCalifornia: Bill(s) of lading, invoice, rail inventory sheet, pipeline company documentation with gas injection and extraction records.
  1. Contracts between fuel producer and distributor, oil company, rail or truck transport company, loading ticket. Documentation supporting transfer of ownership between natural gas/biomethane producer, marketer, liquefaction/compression facility and dispensing station owner.
  1. Additional documents for biomethane-based fuels include:

(a)Official records from the production facility showing production of at least the amount of biomethane sold to California.

(b)Proof of transportation use - contract between California transportation fuel marketer with retail sales outletsshowing that biomethane was supplied for transportation use in California.

(c)Statements from the biomethane suppliers and marketers attesting to the fact that that biomethane is not being used to earn credits under any other state or federal program, with the sole exception of the Federal Renewable Fuel Standard program (RFS2).

  1. LCFS Fuel Producer Legal Responsibility Form (Attached).

The Demonstration of Physical Pathway Form allows you to document this information for ARB’s review and approval and potential use by regulated party.

PLEASE NOTE THAT ANY CONTRACT INFORMATION SUCH AS PRICES AND NAMES OF DISTRIBUTORS, CARRIERS AND PARTIES TO WHOM THE FUEL HAS BEEN SOLD WILL BE TREATED AS CONFIDENTIAL BUSINESS INFORMATION (CBI), IF PROMINENTLY MARKED AS CBI.

Physical Pathway Code and Physical Pathway Description

The Physical Pathway Code Table provides physical pathway code and physical pathway description information to be used for registration and reporting transactions for compliance under the LCFS program.

PHYSICAL PATHWAY CODE TABLE
Physical Pathway Code / Physical Pathway Description
PHY01 / Fuel produced in California
PHY02 / By rail from US to California
PHY03 / By ocean tanker from Brazil to US, then by rail to California
PHY04 / By ocean tanker from Brazil to Caribbean Islands, and by ocean tanker from Caribbean Islands to US, then by rail to California
PHY05 / By ocean tanker from Malaysia to US, then by rail to California
PHY06 / By ocean tanker from Indonesia to US, then by rail to California
PHY07 / By ocean tanker from other country to US, then by rail to California
PHY08 / By truck from US to California
PHY09 / By ocean tanker to California
PHY10 / Physical Pathway Demonstration Approval Pending
PHY11 / By ocean tanker from Brazil to Caribbean Islands, and by ocean tanker from Caribbean Islands to California – then by pipelines from the port in California into storage tanks in California
PHY12 / By pipeline from North America to California
PHY13 / By ocean tanker from Brazil through the Panama Canal to a port in California
PHY14 / By pipeline from North America to a liquefaction facility in North America – then by truck todispensing station in California
PHY15 / By rail from Canada to California

Date:

CompanyName:EPA Company ID:

FacilityName: EPA Facility ID:

Facility Address:

Fuel:

Fuel Pathway Code:

Carbon Intensity (CI):

Physical Pathway Code:

Physical Pathway Description:

Physical Pathway Narrative Description:Include discussion of each company that owns and/or has physical custody of the fuel at each segment of the physical pathway as shown on the map(s) provided

Map(s) showing Route to California and Fuel Transfer along the Route (provide as an attachment)

PHYSICAL PATHWAY DEMONSTRATION TABLE
Physical Pathway Segment Description / Mode of transportation along the segment / Company - role (e.g. producer, shipper, carrier, distributor, importer) / Title Holder / Starting Location / Ending Location / Volume (gallons) / Date at End Location / Documentation Provided and Comments
1
2
3
4
5
Company Name / Mailing Address / Phone Number / Contact Name
1
2
3
4
5

Form may be submitted to: