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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 credits
    • Flexibility and hardship provisions
    • Fuel certification
    • Fuel distributor and blender registration
    • Bulk terminal fuel handling
    • Pipeline fuel specifications
  • Assistance with Renewable Fuel Standard compliance
    • RIN transaction reporting
    • Renewable Volume Obligation (RVO) calculation
    • Economic 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 assessment
    • LCFS market participation and credit transaction management
    • Fuel pathway processing, application, and life cycle analysis
    • LCFS quarterly reporting
    • Credit calculation and economic analysis
    • Verification services and Monitoring Plan preparation
  • Support with CARB's Alternative Diesel Fuel regulation
    • Fuel records and blend data review
    • Quarterly ADF report preparation
    • Regulatory cost analysis
  • Federal and state GHG reporting assistance
    • System registration and GHG report filing in CA, OR, and WA
    • GHG Monitoring Plan preparation
  • 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 

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.

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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