Waste, residue and by‐product definitions for the California Low Carbon Fuel Standard
This report by ICF International was commissioned by ICCT to inform life-cycle treatment of biofuel feedstocks under California’s Low Carbon Fuel Standard (LCFS), as well as biofuel regulations in other jurisdictions. The LCFS currently does not have clearly established rules for identifying how different biofuel feedstocks should be categorized for the purpose of life-cycle analysis (LCA). It can be unclear at present which LCA tools should be used for assessing the upstream carbon intensity of feedstocks that might be described as “by-products,” “residues,” or “wastes.” Indeed, the specific meaning of these terms is not currently well defined in the regulation. For instance, there is no clear rule for when a displacement analysis should be undertaken in cases where a biofuel feedstock had a previous use. This issue is important because these methodological choices can affect how many LCFS credits are awarded to a biofuel.
In this report, ICF has developed recommendations for guidelines to categorize biofuel feedstocks as primary singular products and co-products as primary products, and by-products and wastes/residues as secondary products. ICF recommends that the main criterion for distinguishing primary products from secondary products is whether production of the feedstock is elastic to changes in demand. If increased demand for a feedstock would result in a significant increase in production, that feedstock should be classified as a primary product, and if not, as a secondary product. A singular primary product should be allocated all upstream emissions from feedstock production. A primary co-product is one of multiple products in a process that each have substantial market value and are elastic to demand; each co-product should be allocated a portion of upstream emissions.
Secondary products (with inelastic supply) are split into two categories. By-products are inelastic to demand changes but have significant market value and existing uses other than biofuel production. Wastes and residues have little or no value and are currently typically disposed of. By-products and wastes/residues should not be allocated upstream emissions from feedstock production, but a displacement analysis should be conducted if the material has existing non-energy uses. The displacement analysis should identify the material that would replace the biofuel feedstock in its non-energy uses, and emissions from the increased production of this material should be allocated to the biofuel pathway.
The report also includes case studies of existing biofuel feedstocks for which the categorization may be unclear under the LCFS and other regulations: inedible tallow, inedible corn oil, palm fatty acid distillate (PFAD) and used cooking oil.