RFS Compliance Guidelines and Reporting

Portland's Renewable Fuel Standard

Portland adopted a new Renewable Fuel Standard in 2022. This policy increases low-carbon biofuel blends, moving Portland’s diesel fuel mix to 99% renewable in 2030. This policy includes a carbon intensity standard to shift to fuels that are lower carbon across their entire lifecycle.

• View the policy
• Access supporting administrative rules

State and Federal requirements still apply. There are no new requirements for gasoline – policy updates only apply to distribution and sale of diesel fuel.

Read the Compliance Guidelines and Reporting overview below, or visit these pages for more details:

1. Covered entities defined
2. Retailers and nonretail dealers
3. Distributors and resellers, marketers or jobbers
4. Fuel terminal or fuel importer
5. Wholesale purchaser-consumer

General overview of requirements

Diesel requirements. In order to demonstrate compliance, biofuel content must be advertised for sale and labeled according to state and federal laws. The volume percent of biofuel content must be shown on a bill of lading or product transfer document (PTD) and those records must be maintained at the registered place of business for two years.

Gasoline requirements. These requirements have not changed. All gasoline sold within the City shall contain a minimum blend of 10 percent ethanol (E10 fuel).

Minimum biofuel content reporting. There are no reporting requirements to comply with the minimum biofuel content requirement. Compliance is maintained via random on-site inspections and record keeping at the place of business.

Carbon intensity standard requirements

Diesel requirements: In accordance with the percent volumes mentioned above, all biodiesel and renewable diesel must have a carbon intensity equal to or less than 40g CO2e/MJ as certified by DEQ’s Clean Fuels Program, approved carbon intensity values.

Carbon intensity requirements apply to biofuel blendstock, not the final blended product.

Covered entities will need to comply with the carbon intensity standard through use of either absolute CI value or an average CI value:

• The absolute CI value means the value assigned to the fuel by the Oregon Clean Fuels Program fuel pathway. Absolute CI value can be used for any of the three compliance options.
• The average CI value means the weighted average of CI values from multiple Oregon Clean Fuel Program fuel pathways. This allows covered entities to use fuel from multiple fuel pathways to meet the City’s requirements, if the weighted average of different renewable fuels is equal to or less than the carbon intensity standard over the compliance period. Use of this definition requires either book and claim or delivered fuel summary compliance.

Covered entities may determine the appropriate approach given their business practices. Designation of the approach taken must be documented and attested to by covered entities for each compliance period, by July 1 for 2024 and by January 1 for future years.

Carbon intensity standard compliance and reporting

Covered entities have three carbon intensity (CI) standard compliance options available over the course of the compliance period, which is one calendar year.

CI compliance options include:

1. Book and claim. Covered entities may use book and claim exclusively for compliance with the biofuel carbon intensity standard. This option allows covered entities to comply by demonstrating that on average they have imported into Oregon a sufficient volume of renewable diesel, biodiesel, or a blend thereof that is compliant with the CI standard to satisfy the proportion of renewable fuel sold in Portland, regardless of where the compliant fuel is sold. Book and claim, in this context, does not allow for the banking, trading or other marketable mechanism to exchange environmental attributes. Book and claim compliance allows CI averaging. Book and claim requires quarterly and annual reporting to Bureau of Planning and Sustainability (BPS) and a fuel importer who accepts reporting responsibility on behalf of covered entities. An executed written agreement among parties is also required for this compliance option. Specifics on written agreements can be found in the Administrative Rules Section 6.D and specifics on reporting can be found in Section 6.E.
2. Product transfer documents (PTD). PTD is the general term for the paper trail that documents the transfer of ownership of fuel from one entity to the next. Covered entities selecting this compliance option must include an Oregon Fuel Pathway Code (FPC) on at least one PTD through sale to the fuel retailer or wholesale purchaser-consumer. Under this compliance option, fuel distributors, resellers, retailers, nonretail dealers, or wholesale purchaser-consumers will need to obtain and maintain the FPC, originating from the fuel pathway holder, on at least one PTD associated with each fuel delivery. No reporting required.
3. Delivered fuel summary. A third compliance option for covered entities, delivered fuel summary, allows covered entities to maintain a quarterly summary report of the fuel pathway codes (FPC) associated with each fuel delivery, in lieu of maintaining the FPC on a PTD from each delivery. This option will also enable covered entities to average the CI over the quarter, like book and claim compliance. More information about summary report content can be found in the Administrative Rules Section 6.E.3.

Reporting forms

Sample reporting form information is available on this page. No reporting is due until January 10, 2025. The City will email contacts on the RFS registration list once the final forms become available.

2024 reporting timeline

There are no reporting deadlines for blending requirements. The following timeline outlines reporting requirements for the carbon intensity standard.

Contact us

It is strongly suggested that covered entities review Chapter 16.60 Motor Vehicle Fuels Code and Administrative Rules before contacting the city for assistance.

Questions can be directed to the Renewable Standard Program staff.