The California Air Resources Board (CARB) has resubmitted proposed amendments to the Low Carbon Fuel Standard (LCFS) to the Office of Administrative Law (OAL) to reflect the changes requested by the agency. The revisions were provided to OAL on May 16 and the agency has until June 30, 2025 (30 working days) to make a determination on the revised package.

If OAL approves the rulemaking package and grants CARB’s request for an early effective date, the updated LCFS regulation could be effective on July 1, 2025, instead of the next scheduled effective date of October 1, 2025.

An earlier effective date could help clarify the applicable LCFS annual carbon intensity (CI) standard for 2025 and alleviate market uncertainty regarding the value of LCFS fuels sold into the California market. If the October 1, 2025 effective date is applied, investors may face the challenge of navigating two separate annual CI standards applying to different periods within 2025.

CARB approved amendments to the LCFS on November 8, 2024 and submitted them to OAL for review on January 3, 2025. However, OAL disapproved them on February 18, 2025, citing clarity issues and procedural concerns. In response, CARB released a third 15-day comment period on April 4, 2025, allowing stakeholders to review and comment on proposed modifications aimed at addressing OAL’s concerns. CARB received 81 written comments in response.

Here is a link to the LCFS rulemaking package for more information.