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Regulatory Compliance for Mobile Sources and Fuels

Fuels Regulations Services

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. 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 pathway 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 specification.  Fuel Regulations Support Trinity's fuels regulatory and compliance services include:  Support with federal and state gasoline program compliance Averaging, banking, and trading of sulfur and benzene creditsFlexibility and hardship provisionsFuel certificationFuel distributor and blender registrationBulk terminal fuel handlingPipeline fuel specifications Assistance with Renewable Fuel Standard compliance RIN transaction reportingRenewable Volume Obligation (RVO) calculationEconomic and environmental assessments Compliance assistance with California's Low Carbon Fuel Standard and Oregon's Clean Fuels Program LCFS quarterly credit data analysis and fuel market assessmentLCFS market participation and credit transaction managementFuel pathway processing, application, and life cycle analysisLCFS quarterly reportingCredit calculation and economic analysisVerification services and Monitoring Plan preparation Support with CARB's Alternative Diesel Fuel regulation Fuel records and blend data reviewQuarterly ADF report preparationRegulatory cost analysis Federal and state GHG reporting assistance System registration and GHG report filing in CA, OR, and WAGHG Monitoring Plan preparation Compliance analysis for importers and bulk fuel purchasers Assistance with California Cap-and-Trade requirements Compliance status assessmentBenchmark and allowance allocation calculationsCalifornia GHG and offset project verification services  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 blendersAssistance with written and verbal communications with regulatory agencies  Trinity Can Help - Contact Us Today Trinity's services are customized to meet each client's specific needs. Please contact us for additional information including qualification statements, resumes, and/or client references. For assistance, contact Alex Marcucci at (916) 273-5133.   Related Articles Trinity Consultants is now an Accredited Verification Body for the LCFS Program  -  Feb 27 2020 CARB Cap-and-Trade November 2019 Joint Auction Notice  -  Oct 30, 2019 CARB Proposes Enhanced Cost-Containment for the Low Carbon Fuel Standard  -  May 28, 2019 Cap-and-Trade February 2019 Joint-Auction Results Released  -  Mar 27, 2019 Related Training Free Webinar - How to Prepare for California Low Carbon Fuel Standard LCFS Verification Requirements in 2020 and Beyond Free Webinar - California Low Carbon Fuel Standard Amendments: What You Need to Know Webinar Additional Resources Listen to the latest episode of Convenience Matters where Alex Marcucci discusses how the California Low Carbon Fuel Standard impacts the fuel market.   163 Challenges and Successes With Low Carbon Fuel Standard Programs Alex Marcucci // Managing Consultant // Trinity Consultants


Mobile Source Support

Modeling Analysis, Engine Certification, and In-Use California Fleet Compliance Who Needs Mobile Source Support Services? Trinity provides mobile source support services to companies needing to quantify emission reductions from fuel or vehicle/engine changes, certify engines and equipment for sale in North America, or operate fleets in California. The emission reductions associated with mandatory and voluntary emission control programs involving changes in commercial fuel properties or vehicle/engine components are quantified using one or more mobile source emissions models. Trinity's modeling support may be provided to evaluate compliance strategies, to demonstrate compliance with regulations, and/or to earn credit for voluntary emission reductions. Trinity also offers assistance with the certification of vehicles and engines with U.S. EPA and the California Air Resources Board (CARB), as well as compliance strategy and support for owners/operators of non-road diesel equipment fleets based in California that are subject to CARB's in-use fleet rules and agreements, a list of which is provided below. Mobile Source Modeling Analysis Trinity's team has an extensive history with mobile source emission factor, emission inventory, and vehicle simulation models, covering both model development and model application. These models include U.S. EPA's MOVES, MOBILE, and NONROAD series and CARB's EMFAC and OFFROAD series. We also develop customized versions of MOVES, MOBILE, NONROAD, and EMFAC to address specific client needs and have adapted and implemented a vehicle simulation model, VEHSIM, for a variety of applications. Vehicle and Engine Certification Support Vehicle and engine manufacturers seeking to sell their products in North America must first obtain emissions certification from regulatory agencies including U.S. EPA, CARB, and Environment Canada (EC), and the International Maritime Organization (IMO) for marine engines that operate in designated Environmental Control Areas (ECAs) outside of U.S. waters. Certification requirements apply to a wide range of engines, vehicles, and equipment, including the following: Passenger cars and light-duty trucks Heavy-duty engines and vehicles On- and off-road motorcycles Off-road recreational vehicles and personal watercraft Small spark ignition engines (lawn and garden equipment, etc.) Large spark ignition engines (forklifts, etc.) Non-road diesel engines (e.g., agricultural, construction, and industrial equipment) Marine engines Locomotives Trinity offers education and training to assist engine and vehicle manufacturers with understanding market certification requirements which include emissions testing, durability demonstrations, emission control system warranties, and defects monitoring and reporting. Trinity also assists clients with informing regulatory agencies of manufacturer certification plans, addressing lead-time requirements for vehicle and engine certification and production, and supporting all other aspects of the emissions certification process.  Trinity services include the following: Development of compliance strategies allowing for efficient and timely certification Registration with regulatory agencies Design of deterioration factor (DF) testing plans Assessment of potential certification carryover and carry-across strategies to reduce emission testing burdens and certification fees Coordination of meetings with regulatory agencies Preparation of all elements of certification applications, including:Electronic certification application files in agency-required formatsAuxiliary Emission Control Device (AECD) descriptionsAdjustable parameter descriptions (i.e., Anti-Tampering Controls)NOx technical files (for marine diesel engines)Emission control warranty statementsEmission control labelsSubmission and tracking of complete certification applications In addition, Trinity assists with post-certification regulatory requirements, including production reports as well as defect monitoring and reporting. Additional related services include monitoring of new regulatory requirements, comprehensive reviews of manufacturer certification processes, assistance in responding to enforcement actions brought by regulatory agencies, and management of emissions-related recalls.  In-Use Compliance Support Trinity offers support related to the development of compliance strategies for owners/operators of California-based diesel vehicle and equipment fleets subject to one or more of the following regulations or agreements: 1998 Locomotive NOx Fleet Average Emissions Agreement in the South Coast Air Basin 2005 Statewide Railyard Agreement Concepts to Reduce Emissions from Locomotives and Railyards (regulation under development) Regulation to Reduce Emissions of Diesel Particulate Matter, Oxides of Nitrogen, and Other Criteria Pollutants from In-Use Heavy-Duty Diesel-Fueled Vehicles (Truck and Bus Rule) Periodic Smoke Inspection Program Emission Control Label Inspection Program Regulation Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling California Smog Check Program Regulation for In-Use Off-Road Diesel-Fueled Fleets Large Spark-Ignition (LSI) Engine Fleet Requirements Regulation In-Use On-Road Diesel-Fueled Heavy-Duty Drayage Trucks Regulation for Mobile Cargo Handling Equipment at Ports and Intermodal Rail Yards Airborne Toxic Control Measure for In-Use Diesel-Fueled Transport Refrigeration Units (TRU) and TRU Generator Sets, and Facilities Where TRUs Operate Transport Refrigeration Unit Regulation (regulation under development) Portable Diesel Engine ATCM Portable Equipment Registration Program Trinity Can Help - Contact Us Today Trinity Consultants can assist with a wide range of mobile source modeling and engine certification support services, including mobile source testing, modeling, and certification support. For assistance, please email Jim Lyons or Edward Gardetto or call us at (916) 444-6666. Related Training Engines: Emissions and Compliance Requirements in Louisiana Understanding Engines: Their Emissions and Your Compliance Requirements Related News CARB Focuses on Fleet Rules and Enforcement Phase 2 GHG Emission Standards for Heavy-Duty Vehicles Effective 2020 and Later Models Project Spotlight: KPUD Renewable Natural Gas Project