This guidance document describes how to complete a Carbon Intensity (CI) Application under Section 21 (3) (a) of the Low Carbon Fuels Act (LCFA).
This information bulletin is intended for fuel producers or suppliers that wish to manufacture, sell or import low carbon fuels into British Columbia (B.C.). Fuels supplied in B.C. are reported under the LCFA and its regulations, which are together known as British Columbia’s Low Carbon Fuel Standard (LCFS). For more information on the LCFS please see the LCFS Requirements webpage.
Under Section 13 of the LCFA, recorded carbon intensities (RCIs) calculate the quantity of compliance units issued. There are four types of RCIs:
To obtain an Approved CI, fuel suppliers or producers must submit a CI Application Form and a Technical Report. The CI Application form can be found on the LCFS Carbon Intensities webpage. Applicants must complete the CI Application Form in full. The Technical Report substantiates information provided in the CI Application Form. The required content and format for the Technical Report are outlined in the Section 6.
Multiple fuels can be included on a single application provided they are for products from the same fuel production facility.
The CI Application Form and Technical Report may be authored by the fuel producer or by a consultant/third-party. A Notification of Representation Agreement Form is required for a third-party to sign and/or make amendments to a CI Application on behalf of the Applicant. The form is available on the Low Carbon Fuel Standard credit market webpage.
The CI Application Form and Technical Report must be submitted electronically to lcfs@gov.bc.ca. Both documents must be an attachment in .PDF file type. Include ‘CI Application’ and the production facility name, location and fuel type in the email subject line (e.g. CI Application – XYZFuels Plant – Vancouver – Ethanol). Additional documentation, like GHGenius excel files, may be submitted but is not required. Confirmation of receipt by the Ministry will be sent to the applicant via email. The Ministry does not require a physical copy of the application.
Guidance on renewing existing fuel codes is covered in Section 2.6, below.
Ministry staff will evaluate the application to ensure the methodology and assumptions made are acceptable, and that the carbon intensity can be reproduced. If an error or omission is identified in the application, the applicant will be asked to submit additional information. If the CI changes when correcting the error/omission, the applicant is required to submit a revised Carbon Intensity Application and Technical Report (a resubmission). Applicants must respond to requests for additional information and/or corrections within 8 weeks. Failure to respond within this period may result in rejection of the application, requiring the applicant to restart the application process and resulting in a deferred Effective Date (described in Section 2.4, to follow).
The director will inform the applicant when they have made a decision regarding the Carbon Intensity Application. If approved, the applicant will receive a unique fuel code (e.g. BCLCF301.0, C-BCLCF302.4). Fuel codes for products manufactured in Canada are assigned a “C“ prefix. The Approved Carbon Intensity and fuel code will be posted in RLCF-012: Approved Carbon Intensities.
If the director does not approve the application, staff will contact the applicant and provide the opportunity to address areas of concern to address the issues and/or resubmit the application.
The Effective Date for a fuel code is the earliest date the Approved CI can be used in compliance reporting. In most cases, the Effective Date is the date the application was received by the Ministry.
Fuel codes cannot be backdated past the date of application receipt by the Ministry. To use an Approved CI in compliance unit calculation, the CI Application must be submitted prior to the first date of intended supply.
Fuel codes are assigned a 1-year or 3-year Expiry Date.
Approved applications based on design data, a trial run, or less than 1 year of operational data are eligible for a 1-year fuel code. Those based on 12+ months of operational data gathered within the last 3 years are eligible for a 3-year fuel code. See Section 4.3.1 for additional details. An exception is made in the case of coprocessing, see RLCF-019: Co-processing Methodology.
The Expiry Date for a fuel code is the last day the Approved CI can be used to calculate compliance units. If fuel is purchased prior to or on the Expiry Date, the fuel code remains valid even if delivery occurs after the Expiry Date.
For example, on December 25, 2024, a fuel with a fuel code Expiry Date of December 31, 2024, is purchased. The fuel is transported to the purchaser’s storage facility on January 2, 2025. Because the purchase occurred before the Expiry Date, the fuel code remains valid for that fuel.
In accordance with Section 20 (7) of the LCFA, the director may expire a fuel code early if they become aware that the carbon intensity is inaccurate. If a person who manufactures, supplies or exports fuel with an Approved CI becomes aware that the carbon intensity of the fuel has changed or will change, the person must immediately provide written notice to the Ministry.
A renewal application is required for expired fuel codes even when the fuel pathway has not changed. To avoid a gap in approval, a renewal application must be submitted the day after the Expiry Date or sooner.
For example, if a fuel code expires on November 14, 2025, to avoid a gap in approval, a renewal application must be received on or before November 15, 2025. If the renewal application is received on November 26, 2025; the updated fuel code (if approved) is effective November 26, 2025. There would be an 11-day gap in approval during which the fuel supplier is required to use the default CI for this fuel type for compliance unit calculation.
When a renewal application is received prior to expiry, the Effective Date may be set to the application date, or the days following expiry of the existing fuel code provided the latter is no more than 90 days after the application date. If an alternate Effective Date is sought, contact Ministry staff. In no circumstances can the Effective Date be set prior to the application date.
A renewal application requires submission of a CI Application Form and Technical Report. The submission and review procedures are the same as for new CI Applications. When applying for a renewal, applicants must include the previous fuel code on the CI Application Form and must include a comparison and explanation of all changes to the inputs and results compared to the previous application.
An approved renewal application results in the creation of a decimal fuel code. For example, BCLCF101.0 becomes BCLCF101.1. The Approved Carbon Intensity and fuel code will be posted in RLCF-012: Approved Carbon Intensities.
In accordance with section 20 (6) of the LCFA, if a person who manufactures, supplies or exports fuel with an Approved CI becomes aware that the carbon intensity of the fuel has changed or will change, the person must immediately give written notice to the Ministry. This may occur if an error is discovered in the data that supported the original application, if there are changes in the fuel production pathway, or changes to transportation modes and distances of feedstock or fuel, among other reasons.
A new application is required if the carbon intensity of a fuel has changed or will change. When applying for an update, applicants must ensure that the previous fuel code is stated on the CI Application Form and include a comparison and explanation for changes to the inputs and results when compared to the previous application.
In some cases, a fuel producer may prefer to apply for a second fuel code to reflect the development of a new or alternate process. For example, if a company producing ethanol using grain from Saskatchewan changes to a grain supplier from Iowa, the company could apply for an update to the existing fuel code if the change is permanent, or the company could apply for a second fuel code to allow flexibility to revert to their original supplier.
Fuel producers may be audited to verify the accuracy of their carbon intensity claims. If an Approved Carbon Intensity is found not to accurately represent the lifecycle emissions of the fuel, the carbon intensity may be updated immediately by the director.
When a carbon intensity update is required due to a change in legislation or a change in the approved version of GHGenius (see Information Bulletin RLCF-011: Approved Version of GHGenius and Global Warming Potentials), the director will notify fuel suppliers of the intent to change and will conduct consultations, as appropriate, regarding the expiration of fuel codes.
GHGenius is the life cycle assessment (LCA) model applicants must use to calculate carbon intensity in the LCFS. Refer to RLCF-011: Approved Version of GHGenius and Global Warming Potentials for the correct version of GHGenius.
Consult the GHGenius model website and the Low Carbon Fuel webpage for additional information on how to use the GHGenius model to determine the carbon intensity of a fuel. GHGenius User Guides are also available to assist applicants in modelling specific fuel pathways.
Fuel producers manufacturing fuel from multiple feedstocks must obtain a separate fuel code for each feedstock pathway. Feedstocks originating in different regions must be modelled as separate feedstocks. Applicants must be as specific as possible when selecting Regions in the GHGenius model (e.g. use “Alberta” rather than “Canada West”). Although each feedstock pathway must have its own fuel code, facility operating data using mixed feedstocks may be used as inputs in the fuel production stage.
Eligibility for 1 or 3-year fuel codes is determined by the extent of operational data available for the fuel production stage. Applicants must use the most recent, representative operational data available. Applicants may use design or trial run fuel production data when no operational data is available. Use of design and trial run data is restricted for renewal applications. The eligibility requirements and limitations on the use of design and trial run data are discussed below and summarized in Table 4.1.
| Fuel Production Data Available | Eligibility | Restrictions |
|---|---|---|
| 12+ months of operational data | 1-year or 3-year | Applicants must use 12+ months of operational data. |
| <12 months of operational data | 1-year | Applicants must use the available operational data. |
| Operational data for some modelling inputs | 1-year |
Applicants must use the available operational data. The Technical Report must clearly state which inputs are based on operational data, design/trialrun data, and model defaults. |
| No operational data | 1-year |
New applications may use design/trial-run data. Renewal applications may use design/trial-run data if no fuel was supplied to B.C. under a prior code. Rationale for why no fuel was supplied must be provided. Renewal applications must use operational data if fuel was supplied to B.C. under a prior code. |
GHGenius comes prepopulated with default data. Applicants must replace default values with data specific to their fuel pathway. This may be operational, design, or trial run data, subject to the restrictions outlined in section 4.3.1.
If using operational data, applicants must set the target year and base year in GHGenius to reflect the year the data was collected. If the data was collected over multiple calendar years, applicants must set the year to the latest year represented by the dataset. If applicants use design data, they must set the target and base year to the year the application was submitted.
Applicants must apply the following data quality principles for all data used to inform the modelling inputs of their proposed fuel pathway:
Applicants may encounter difficulty collecting data. If fuel-path-specific values cannot be obtained, applicants should use the default values from GHGenius and explain why fuel-path-specific data was not available in the Technical Report.
Other non-operational data may be used if it is more representative than the default values provided the applicant includes sufficient justification in the Technical Report. The rationale must explain the representativeness and conservativeness of the data used.
An example of where this may occur is when instrumentation for measurement does not exist at the production facility in the application, but the applicant has instrumentation readings for the same process at another similar production facility.
For information on the data requirements for co-processing, supplying liquified or compressed natural gas to B.C., the use of Proxy CIs, and avoided emissions refer to the following Information Bulletins & User Guides:
Section 21 (3) (b) of the LCFA allows for the determination of a carbon intensity by alternative methods accepted by the director. Refer to information bulletin RLCF025: Use of Alternative Methods for Determining Carbon Intensities for further information on alternative methods.
Carbon Intensity Applications are confidential and will not be posted on the Ministry website.
The Low Carbon Fuels (General) Regulation allows publication of proposed and approved alternative methods. This allows alternative method proposals to be published for public review prior to use by the applicant and allows the alternative method to be used by other fuel manufacturers, once approved. This helps to ensure fairness of methods used for quantifying the carbon intensity between fuel manufacturers using similar technologies or pathways.
The Technical Report must explain and provide rationale for all input values used in the model. It must address all fuel path-specific information requirements outlined in the GHGenius user guides and relevant information bulletins (e.g. RLCF-019 Coprocessing Methodology), as applicable. The report must explain all assumptions, calculations, derivations, analysis, and operational data collection methods used to obtain the model input data. When model defaults are used, the author must explain why pathway-specific data was not available.
Excel worksheets used to calculate model input data may be submitted with the application; however, all calculations must be referenced and explained in the Technical Report. Information should be clear and concise:
The following information is not required:
If applying to renew a previously approved fuel code, the Technical Report must:
The following report sections must be included. Additional sections may be added as needed.
1. Roles & Responsibilities
2. Introduction
3. Feedstock Production and Transportation
4. Fuel Production and Transport of Finished Fuel

5. Distribution, Dispensing and Use in B.C.
6. Material Balance – Fuel Production Stage
The tables must include the following columns at minimum:
Stream name: Name/describe the flow (e.g. canola oil, make-up hydrogen, renewable diesel, renewable naphtha, off-gas).
Moisture content: For streams where moisture content is variable, include a column for moisture content.
Inputs/Outputs: Provide quantity both in g/unit and in the units entered in GHGenius, where applicable (e.g. naphtha coproduct quantity is listed in grams and litres per unit of the main fuel). Where streams have variable moisture content, provide the inputs and outputs on a dry-mass basis. Unit conversion must be done using conversion factors from GHGenius. If alternate conversion factors are used, state them in the notes column and provide rationale for using alternate conversion factors.
Function: List the type of flow/material (e.g. renewable feedstock, fossil feedstock, chemicals/additives, main product, co-product, captured CO2).
Notes: This column contains composition or property information where relevant, and any other important information about the stream. Examples of information to be included are listed below:
| Input Stream | GhGenius Location | GhGenius Input | Input (g/LHDRD) | Function | Notes |
|---|---|---|---|---|---|
| Canola oil & soy oil | Input CD248 | 0.95 kg/LHRD | 950 | Renewable feedstock | |
| Hydrogen | Alt Fuel Prod CM44 | 0.015 kg/LHRD | 150 | Feedstock | |
| Total Input | 1100 | ||||
| Output Stream | GhGenius Location | GhGenius Input | Output (L/HDRD) |
Function | Notes |
|---|---|---|---|---|---|
| HDRD | N/A | N/A | 782 | Main Product | |
| Naphtha | Coprods BC137 | 0.150 L/LHRD | 102 | Coproduct | ρnaptha: 678g/L (GHGenius value) |
| LPG | Coprods BC135 | 0.806 L/LHRD | 41 | Coproduct | ρLPG: 509g/L (GHGenius value) |
| Fuel gas | Coprods BC141 | 0.012 kg/LHRD | 12 | Coproduct | |
| Waste gasses |
N/A |
N/A | 163 | Waste | Unmetered streams. Calculated using material balance. |
| Water | N/A | N/A | Waste | ||
| Total Output | 1100 | ||||
7. Modelling Results
| Modelling Outputs for: New Code 1 | |||||
|---|---|---|---|---|---|
| Result Location (Column ##, or out-of-model calc.) |
Source of Emissions | Feedstock Production | Fuel Production | Fuel Use & Distribution | Total |
|
- |
Analysis Region | US Central | US West | BC | |
| - | Fuel | HDRD | HDRD | HDRD | |
| - | Feedstock | Tallow | Tallow | Tallow | |
| AK | Direct land use change | 0 | 0 | ||
| AK | Feedstock production or cultivation |
0 | 0 | ||
| AK | Feedstock upgrading | 19,248 | 19,248 | ||
| AK | Feedstock transport | 2,442 | 2,442 | ||
| AK | Feedstock coproduct production | -10,460 | -10,460 | ||
| AK | Avoided emissions | 0 | 0 | ||
| AK | Fuel production | 11,285 | 11,285 | ||
| AK + out-of-model calc. | Fuel coproduct production | -961 + (-573) | -1,524 | ||
| AK | Fuel distribution and storage | 838 | 395 | 1,233 | |
| AK | Fuel dispensing | 82 | 82 | ||
| AK | Vehicle or vessel operation | 1,524 | 1,524 | ||
| - | Total (gCO2e/GJ) | 23,819 | |||
| - | Total (gCO2e/GJ) | 23.82 | |||
8. Appendices
This information is for your convenience and guidance only and does not replace or constitute legal advice. It is recommended that parties who may be a fuel supplier review the Low Carbon Fuels Act, Low Carbon Fuels (General) Regulation and the Low Carbon Fuels (Technical) Regulation and seek independent legal advice to confirm their status, legal obligations and opportunities.