As RNG projects scale, operators need reliable SCADA systems to manage complex facilities.We break down the most common platforms used in the industry and how teams select them.
A practical guide for renewable fuel producers, feedstock suppliers, farmers, traders, and consultants operating in the California Low Carbon Fuel Standard program.
Before understanding the new attestation requirements, it helps to understand exactly what a Specified Source Feedstock (SSFS) is — and why it matters for your pathway's carbon intensity score.
Under the LCFS, certain feedstocks qualify for a reduced carbon intensity (CI) value because they are waste materials, residues, or by-products of other commercial or industrial processes. These are called Specified Source Feedstocks, and they can significantly increase the credit value of a fuel pathway when properly documented and verified.
CARB recognizes four main categories of specified source feedstocks:
SSFS pathways can qualify for a reduced CI score, making them especially valuable for producers seeking to maximize LCFS credit generation. But with this benefit comes stricter oversight — producers must now provide evidence of chain of custody from the point of origin all the way through delivery to the fuel production facility.
For pathway holders using specified source feedstocks, the amended LCFS regulations require maintaining chain-of-custody evidence covering every link between the point of origin and the fuel production facility. This evidence must be provided to verifiers and to CARB upon request.
Chain-of-custody evidence takes one of two acceptable forms: delivery records showing feedstock type and quantity shipped directly from origin to the fuel facility, or records from material balance and energy balance systems that track and assign input characteristics to output quantities at each relevant stage of the supply chain.
Each party in the SSFS supply chain — whether a pathway holder, joint applicant, or supply chain partner — must meet the following documentation requirements to remain eligible under a specified source pathway:
Every feedstock transaction must be accompanied by a Feedstock Transfer Document that clearly states the following information:
These documents form the foundation of the traceability record. Without them, the chain of custody cannot be demonstrated — and without a demonstrable chain of custody, the reduced CI value associated with the SSFS pathway is at risk.
Under the amended LCFS, every entity involved in handling a specified source feedstock must maintain a supplier attestation letter. This covers the full sweep of the supply chain: points of origin, collectors, aggregators, traders, distributors, and storage facilities involved from the feedstock's origin through delivery to the fuel producer.
An attestation letter is not a generic statement of intent. It must satisfy three specific requirements:
The attestation must confirm that no additional processing — such as drying, cleanup, or upgrading — has been applied to the feedstock beyond what is explicitly included in the pathway's lifecycle analysis and certified carbon intensity value. Any undisclosed processing can invalidate the pathway's CI assumptions.
The letter must attest that the feedstock meets the definitions approved by CARB during pathway validation and certification, that deliveries match the associated Feedstock Transfer Documents and have not been mixed with other materials, and that the feedstock was not intentionally produced, modified, or contaminated in order to qualify as a specified source feedstock.
Beyond content, the attestation letter itself must meet formal standards:
Pathway holders must also sign attestation letters tracing feedstock back to the point of origin, and maintain documentation for every entity in the supply chain — from origin through collectors, aggregators, traders, distributors, storage facilities, transportation method, and mileage. These letters must be provided to CARB verifiers or the Executive Officer upon request.
The most important thing to understand about these amendments is what they are actually doing: they are pushing compliance risk out of the fuel production facility and into the feedstock supply network — a network that pathway holders often do not directly own or control.
Think about how a typical renewable diesel or sustainable aviation fuel supply chain actually works. A fuel producer may source used cooking oil from dozens or even hundreds of restaurants, collected by third-party haulers, aggregated at intermediate facilities, and then delivered by yet another logistics provider. Each of those parties is now part of the compliance record.
if any link in that supply chain cannot produce adequate documentation, the consequences fall on the pathway holder — not the collector or aggregator.
Collectors, aggregators, and feedstock brokers typically operate under much less regulatory scrutiny than fuel producers. Their recordkeeping systems may be informal, inconsistent, or simply not designed to meet verification standards. That mismatch is now a direct liability for any pathway holder depending on their feedstock.
The stakes are significant. If a CARB verifier cannot confirm and substantiate feedstock origin using the provided attestation documents, the outcome is not simply a request for additional paperwork. The verifier may determine that the lifecycle calculations underlying the pathway are unverifiable — or that the carbon intensity assumptions cannot be supported. When that happens, the pathway holder does not just face an audit finding: they face lost LCFS credits.
There is an additional layer of complexity that is easy to overlook: CARB has not issued detailed, prescriptive guidance on exactly how verifiers should review feedstock attestations under the new rules. This creates meaningful variation in verification practices across the industry.
For a used cooking oil pathway, one verifier might confirm a restaurant's existence by locating it via satellite imagery. Another might require the pathway holder to validate 20% of source restaurants — contacting each one individually to confirm the business relationship, the volumes of UCO supplied, and any supporting transactional records.
These two approaches are not equivalent. They result in very different audit burdens, very different levels of overhead, and very different levels of credit risk for the pathway holder. Until CARB issues clearer guidance, pathway holders must be prepared for a more demanding standard — because that is what some verifiers are already applying.
The prudent approach is to build your compliance systems to the higher bar, not the lower one.
You are the entity that signs the attestation letters and stands behind the documentation. Your LCFS credit generation depends on the integrity of records that, in many cases, are held by third parties. This means your compliance exposure is now partly determined by the operational maturity of your suppliers.
If your feedstock suppliers cannot produce clean, consistent documentation on demand, your verification outcomes will suffer. It is no longer sufficient to collect attestation letters at the start of a supplier relationship and file them away. Attestation management must be an ongoing operational function — not a one-time onboarding task.
You are now a critical node in the compliance system for your customers. Pathway holders are increasingly asking their supply chain partners to meet documentation standards that may be unfamiliar to businesses that have traditionally operated in less regulated environments.
If you collect used cooking oil from food service businesses, agricultural waste from farms, or other eligible feedstocks, you should expect your customers to ask more questions — and to ask them more frequently. Building clean, auditable records of your collection activities, source relationships, and logistics is not just good business practice. It is rapidly becoming a requirement for staying competitive as a supplier to LCFS-regulated customers.
For farmers supplying agricultural residues, cover crops, or other biomass feedstocks to LCFS pathways, the new requirements mean that your role in the compliance chain is more visible than before. Buyers will need to document your operation as a named point of origin, confirm your location and relationship with the supply chain, and potentially verify the volumes and type of material you supply.
Being prepared to provide basic documentation — records of what you supplied, when, and in what quantities — will make you a more reliable and attractive supplier to pathway holders navigating LCFS compliance.
Given these changes, the industry needs to stop thinking about feedstock attestations as forms and start treating them as a compliance system. Here is a practical framework for doing that:
Confirming that a restaurant, farm, or other source location exists is not a one-time onboarding task. Businesses close. Relationships end. Sources go inactive. Pathway holders should build a recurring verification process — at minimum annually — to confirm that every listed point of origin in their supply chain is still active and still associated with the relevant volumes of feedstock.
Keep a current, up-to-date list of all suppliers, collectors, aggregators, and logistics providers in your supply chain — and use a traceability platform to manage it dynamically. A good system tracks which sources are active, flags inactive or unverified entries, and keeps your supplier data current without relying on manual spreadsheets. Gaps in this registry become gaps in your attestation, and gaps in your attestation become potential credit risks.
Many small collectors and feedstock aggregators do not have the internal systems to maintain the records that LCFS verification now demands. Rather than waiting for suppliers to build those capabilities on their own, onboard them onto a shared traceability platform where documentation standards are built in. When the system guides the process, even suppliers without strong compliance backgrounds can produce consistent, audit-ready records — and the investment pays off in smoother verifications across your entire network.
Do not rely on manual reviews to catch missing or inconsistent feedstock documentation. A traceability platform with periodic reminders and automated gap-flagging will surface incomplete records, missing attestations, or lapsed supplier information on an ongoing basis — so issues are identified and resolved in real time, not discovered mid-audit. Addressing those gaps proactively is far less costly than remediation after the fact.
The most effective way to be audit-ready is to never have to scramble for records in the first place. When suppliers use a shared documentation management tool, attestation letters are completed and transaction records are uploaded at the time of each transfer — not reconstructed weeks or months later. That means every handoff in the supply chain is captured, organized, and accessible the moment a verifier asks for it. Suppliers spend less time hunting for paperwork, and pathway holders gain confidence that the compliance record is complete.
These attestation requirements are part of a broader trend in how CARB is approaching LCFS oversight. As the program matures and credit values remain significant, the agency is strengthening verification rigor across all aspects of the program — not just feedstock documentation. Pathway holders and their supply chain partners should expect this direction to continue.
Companies that build robust compliance infrastructure now — documentation systems, supplier engagement programs, internal audit processes — will be better positioned as the regulatory environment continues to evolve. Those that treat compliance as a cost to minimize will face increasing friction, audit risk, and potential credit losses as verification standards tighten.
The renewable fuels industry has an important role to play in California's clean energy transition. Meeting that challenge requires supply chains that are not just operationally efficient, but compliance-ready at every level — from the fuel producer all the way back to the farm, the restaurant, or the feedstock collection site.
Rimba's compliance software gives renewable fuel pathway holders, auditors, feedstock suppliers, traders, and consultants a single platform to simplify the end-to-end documentation demands of LCFS and other low carbon fuel programs. From generating attestation letters and maintaining chain of custody across every feedstock transfer, to mass balance tracking and structured recordkeeping built for audit, Rimba eliminates the manual, fragmented processes that create verification risk. With a built-in online audit checklist, users can proactively identify and close compliance gaps before a verifier does — turning what was once a scramble into a system.
About This Article
This article is intended as an educational resource for renewable fuel producers, feedstock suppliers, farmers, and others operating in or supplying the California LCFS program. It is based on analysis of the July 1 LCFS amendments and industry experience with LCFS verification practices. It does not constitute legal or regulatory advice. Readers should consult qualified compliance professionals for guidance specific to their operations.
FactoryTalk is one of the most widely used SCADA platforms in North American industrial automation.
Many RNG plants rely on Allen-Bradley PLCs, making FactoryTalk a natural choice due to its tight integration with Rockwell control hardware.
Ignition has rapidly become one of the fastest-growing SCADA platforms in the industrial automation sector.
Unlike traditional SCADA systems, Ignition is built around web-based architecture, making it well suited for remote monitoring and multi-site operations.
GE’s iFIX platform has long been used in industrial process monitoring.
In RNG facilities, it is often deployed in plants that require strong data historian capabilities and integration with existing industrial automation infrastructure.
GE’s iFIX platform has long been used in industrial process monitoring.
In RNG facilities, it is often deployed in plants that require strong data historian capabilities and integration with existing industrial automation infrastructure.
AVEVA’s System Platform (formerly Wonderware) is widely deployed in industrial automation environments.
The platform is known for strong visualization and process monitoring capabilities, making it common in facilities that require detailed operational dashboards.
VTScada is frequently used in infrastructure monitoring environments such as water utilities and gas distribution networks.
Some RNG operators deploy VTScada for remote monitoring of distributed digester systems.
Selecting the right SCADA platform for an RNG facility depends on several operational and technical factors. While most SCADA systems provide similar core functionality, operators typically prioritize compatibility, scalability, and data accessibility.
Most RNG plants rely on programmable logic controllers (PLCs) to control equipment such as digesters, gas upgrading systems, compressors, and pipeline injection infrastructure.
As RNG portfolios expand, many operators manage multiple facilities across different regions.
In these cases, centralized monitoring becomes increasingly important. Platforms such as Ignition and FactoryTalk are commonly used to monitor multiple RNG plants from a single operations center.
Operators often spend hours each day interacting with SCADA screens, especially in facilities where digesters, upgrading systems, and compressors must be monitored continuously. When interfaces are poorly designed or cluttered, it becomes much harder to identify problems quickly.
The RNG industry is still relatively early in its digital transformation.
Most facilities today rely heavily on SCADA systems that were originally designed for industrial process control, not for portfolio-level operational insight.
As operators scale to dozens of plants, a new category of software is beginning to emerge on top of SCADA systems.
These platforms focus on:
Rather than replacing SCADA, these tools use SCADA data to provide higher-level operational intelligence across multiple plants.
For operators managing growing RNG portfolios, this additional software layer is becoming increasingly important.