CARB-Accredited Lead Verifiers

• California’s Office of Administrative Law (OAL) approved a Final Regulation Order on January 4, 2019 that made several changes to the California LCFS. These changes included, but were not limited to, addition of a requirement for registrants within the LCFS to obtain third-party validation of applications for new pathways. Beginning in 2019, new pathway applications would need to be completed using the latest carbon intensity model (CA-GREET3.0) and any application not approved by the California Air Resources Board (CARB) by December 31, 2019 would need to be validated by a CARB-Accredited verification body prior to approval by CARB. The rule also required pathway holders with outdated registrations (i.e., pathways based on CA-GREET2.0) to register for a new pathway under the latest version of the LCFS using CA-GREET3.0. CA GREET2.0 fuel pathways may not be used for reporting fuel transactions after December 31, 2020. The latest LCFS regulation also requires verification of annual fuel pathway reports starting with the 2020 reporting year (these reports are due March 31, 2021). Merjent has engineers accredited by the CARB as lead verifiers under the California LCFS program. Merjent is actively performing verification services with our verification body partner for various renewable fuel producers across the United States.

LCFS Applications

• Merjent assists renewable fuel producers to complete their LCFS pathway application and generate the necessary documentation (e.g., compliance monitoring plans). Merjent also helps producers through the online submittal process and (as applicable) the third-party validation process. The third-party validation process involves an audit-like review of the application materials and a site visit by the verification/audit team. Merjent is here to help answer questions throughout the validation process.
• Merjent staff also use their first-hand experience with the production process technologies to help guide producers through the regulatory requirements and best address them without creating new, unnecessary burden on the producer.

LCFS Documentation

• Producers must maintain specific documentation as a part of their LCFS pathways. Merjent staff help to review the existing documentation and implement means of tracking the necessary process information for these programs.

Regulatory Guidance

• We often consult with our clients on the regulatory requirements of these LCFS programs. With so many programs, each operating under different rules, it can be difficult to keep them all straight. Whether you are wondering about ways to lower your carbon intensity, whether a facility modification will qualify for a provisional pathway, or other course-of-business situations, our engineers can help guide you through the regulations.

Third-Party Engineering Reviews

• Merjent is a leader in RFS2 third-party engineering reviews. Our engineers have performed dozens of these reviews for producers of many different renewable fuel pathways. We perform engineering reviews for facilities all over the country in many different phases of production (e.g., initial registration, triennial registration updates with RIN validation, efficient producer registration, site-specific pathway registration). Hiring Merjent to perform your RFS2 engineering review ensures a professional review that accurately summarizes your production process and contains all the elements that the U.S. Environmental Protection Agency (EPA) requires.

Site-Specific Petition

• Merjent has completed site-specific petitions for many different fuel production pathways. Whether your facility wishes to register a new pathway not listed in Table 1 of 40 CFR 80.1426 or plans to use a combination of pathways that require specific EPA approval, we will use our knowledge and experience of the RFS2 registration process to help you maximize the RIN value for your facility.

Efficient Producer Petitions

• Merjent has developed efficient producer pathway (EPP) petitions and compliance monitoring plans (CMPs) for numerous producers using our extensive experience with the dry mill ethanol production process and the RSF2 regulation. If you are approaching your grandfathered baseline volume, Merjent can help you evaluate the EPP and other compliance options.

CDX Guidance

• Merjent staff have worked with the EPA’s central data exchange (CDX) program for many years. We understand that it can be confusing. As a client, you will receive one-on-one guidance by email, phone, or video conferencing (real-time sharing of computer screens) to complete your initial CDX registration, edit your RFS2 registration, or submit your triennial registration update.

Regulatory Guidance

• We often consult with our biofuel clients on the regulatory challenges they face under the RFS2. Whether you are wondering about the allowable feedstocks under your current registration, the deadline of your next registration update, or just wondering if your facility is compliant with the RFS2, our engineers can help guide you through the regulation.