Environmental Consulting
Compliance Support with Fuels Regulations
Given the complexities, compliance with fuel regulations requires an in-depth knowledge of all the pertinent federal and state requirements. Trinity's fuel specialists have this expertise and provide a wide range of services related to fuel regulations compliance to refineries, biofuel producers, bulk fuel traders, third-party resellers, importers, and distributors.
Our experienced staff assists clients from regulatory inception to litigation challenges. We attend public workshops, produce digests of regulatory requirements and actions, and assist clients in drafting comments and testimony on proposed regulations and amendments. In addition, we provide expert technical support to clients involved in litigation challenging new or amended regulations, as well as in government enforcement actions and relevant commercial disputes.
Trinity's fuels regulatory and compliance services include:
- Support with federal and state gasoline program compliance
- Assistance with Renewable Fuel Standard compliance
- Compliance assistance with California's Low Carbon Fuel Standard and Oregon's Clean Fuels Program
- Support with CARB's Alternative Diesel Fuel regulation
- Federal and state GHG reporting assistance
- Compliance analysis for importers and bulk fuel purchasers
- Assistance with California Cap-and-Trade requirements
- Miscellaneous Support
- CVS monthly newsletter covering all California regulatory events and activity related to fuels and mobile sources (available by subscription)
- Customized updates on all new federal and state regulatory activity (workshops, workgroup meetings, panel meetings, public meetings, Board hearings, seminars etc.)
- General education and training services to fuel producers, importers, marketers, distributors, and blenders
- Assistance with written and verbal communications with regulatory agencies
Cap-and-Trade Services
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Who May Need Fuel Regulatory Support and Why?
Transportation fuel producers, importers, marketers, distributors, and blenders must comply with a multitude of regulatory requirements set forth by the U.S. EPA and state agencies. These requirements can vary from state to state and apply based on where a fuel company is in the distribution system. Federally, fuel producers and distributors must comply with Tier 3 fuel content requirements that apply to conventional gasoline and diesel fuels, as well as with the Renewable Fuel Standard (RFS).
Doing business on the West Coast is particularly challenging, with many states imposing similar but different requirements on gasoline and diesel fuel producers and importers, biofuels blenders, fuel marketers, and distributors. The ever-changing nature of the California Low Carbon Fuel Standard (LCFS), first adopted in 2009, makes it particularly difficult to keep up and remain in compliance. The LCFS requires gasoline and diesel fuel producers and importers to reduce the carbon intensity of transportation fuels by blending biofuels or participating in the LCFS credit market.
Besides cumbersome reporting requirements, LCFS requires a thorough life-cycle assessment for every alternative fuel sold in California before any credits can be generated and monetized. Beginning 2021, third-party verification of reported data and fuel pathways will also be required. Further complicating compliance is the fact that California transportation fuel suppliers are also subject to CARB's Greenhouse Gas Reporting and Cap-and-Trade regulations. Similar but separate programs apply in other states, including Oregon. The Puget Sound region in Washington is planning to adopt a similar program in 2020. Biodiesel blenders in California are subject to the Alternative Diesel Fuel (ADF) regulation, adopted by the California Air Resources Board (CARB) in 2015, which requires affected parties to mitigate NOX emissions from biodiesel blends. Importing fuels into California is also complicated by CARB's fuel certification requirements and stringent fuel specifications.
Perspectives
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