Air and Radiation EPA420-B-06-003 

March 2006 

Guidance on 

Mobile Facilities 
EPA420-B-06-003 

March 2006 

Guidance on Mobile Facilities 

Assessment and Standards Division 

Office of Transportation and Air Quality 

U.S. Environmental Protection Agency 
Guidance on Mobile Facilities 

This guidance document pertains to the revisions of § 80.502, § 80.597, § 80.600, and 

§80.602, which are contained in a Direct Final Rulemaking that was signed on 

November 8, 2005 and published in the Federal Register on November 22, 2005 ; this 

document is intended to supplement the regulation to assist entities within the 

regulatory requirements of mobile facilities. 

For a complete listing of the regulations, please visit the Electronic Code of Federal 

Regulations.

The technical amendments to the regulations allow entities to register mobile 

components that transport their fuel as one or more mobile facilities. During discussions 

with parties in the fuel industry, it became evident to EPA that it could be extremely 

difficult for every vessel (or “mobile component”) owner/operator that transports fuel to 

register for the purposes of designate and track (D&T). This could prove especially 

difficult for those companies that tend to lease mobile components on a short-term basis 

or use a different carrier each time they must transport fuel. While some entities 

indicated that they had situations where it actually would be easier for them to have the 

owner/operators register, EPA has issued a technical amendment that will allow entities 

to register contracted mobile components as one or more “mobile facilities”. 

Vessel owners/operators may still register with EPA as separate entities and 

facilities. In this case, each owner/operator is responsible for all requirements associated 

with D&T, including recordkeeping, reporting, and volume balance accounting. 

• Mobile components are (and are not necessarily limited to): barges, ships, trucks, 

and rail cars; and these vessels can be domestic or foreign 

• The regulations will now allow an entity to combine various mobile components 

and register them as a ‘virtual’ facility 

- An entity must obtain the required 4-digit Entity ID and 5-digit Facility 

ID(s) by submitting the proper registration forms to EPA 

- As with other facilities, each mobile facility must be referenced in 

required recordkeeping and reporting documents by a 9-digit identification 

number resulting from the combination of [Entity ID][Facility ID]

• Mobile components may be defined and combined by an entity as it best sees fit 

- For example: 

◦ an entity may combine all mobile activities together (e.g., “Acme 

Fuels Mobile Operations” could consist of the 2 trucks and one rail 

car that Acme Fuels contracts to transport its fuel) 

◦ an entity may segregate mobile facilities by mobile component 

type, and have multiple registrations (e.g., “Acme Fuels Trucking” 

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would consist of only the trucks that transport its fuel and “Acme 

Fuels Rail” would consist of only the rail cars) 

◦ an entity may segregate mobile activities by area (region, route, 

waterway, etc) and register multiple facilities (e.g., “Acme Fuels 

East Coast” and “Acme Fuels West Coast”) 

◦ an entity may also use a combination of these (e.g., “Acme Fuels 

Trucking- East Coast” would consist of only the trucks that Acme

Fuels uses to transport its fuel in the East Coast area that it defined 

in its registration)

- Regardless of how an entity registers its mobile operations, a description 

and/or diagram should be provided to describe the nature of the mobile 

facility (if registering multiple facilities by area this should include a 

detailed description/diagram of the area(s) that define the mobile facilities’ 

boundaries) 

- If an entity both owns and contracts/hires mobile components, these may 

not be combined in the same mobile facility registration. Entity-owned 

components should be put into a separate mobile facility(s) from those 

operations in which an entity hires/contracts an owner/operator to 

transport its product 

◦ Facilities comprised of owned mobile components may be 

aggregated with the entity’s other owned stationary facilities, per 

the aggregation requirements of § 80.502 

• Registration for these mobile facilities need not contain information on the exact 

number of the mobile components or information regarding the specific 

companies contracted 

- Mobile components and contracts with various owner/operators of 

mobile components can be added/deleted from the facility without 

the need to notify EPA 

- These mobile components will thus be able to transport product for 

the registered entity without the mobile component, or its 

owner/operator, being registered with EPA 

- Contract information with these mobile vessels should be retained 

by the entity that registered the mobile facility 

◦ EPA reserves the right to request this information at any 

time 

◦ An entity must also keep any other records that would be 

probative in the case of a D&T or standards violation (such 

as shipping records) 

• All facility registration, recordkeeping, and reporting are the responsibility of the 

entity that registered the mobile facility 

- The ‘tracking’ portion of D&T, and reporting, must be done by the 

registered entity, not the owner/operators of the mobile components 

- Volume balance requirements must be satisfied 

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- To report volumes, an entity would: add up all hand-offs for all mobile 

components, included under a given mobile facility’s registration, received 

and report the total as “receipts;” add up all hand-offs for all mobile 

components, included under a given mobile facility’s registration, 

delivered and report the total as “deliveries” 

◦ For example, a mobile facility “Acme Fuels Trucking- East Coast” 

would report the total volume moved (whether standing contracts 

with truck owner/operators, or a last-minute acquisition of extra 

space on a truck), rather than the volume put on each specific truck 

(records would still need to be maintained by the registered entity 

though) 

◦ If a mobile facility is defined by a certain area in its 

registration, the volumes of fuel that can be counted as 

receipts or deliveries can only be operations that occurred 

within the boundaries defining that facility (e.g., volumes 

of fuel that are reported as received or delivered by Acme

Fuels Trucking- East Coast can only be from those truck 

movements that occurred within the East Coast 

‘boundaries’, as defined in the facility’s registration) 

• Hand-offs and Transfers of Custody or Title

- PTDs for mobile entities are similar to any other hand-off that occurs with 

stationary facilities 

◦ The entity and facility registration numbers given by EPA should 

be used on PTDs 

- In situations where the recipient/transferee is unknown until the point of

delivery, a PTD may be issued at that point 

◦ In situations where a contracted mobile component of one mobile 

facility transfers fuel to a contracted component of another mobile 

facility, a point-of-delivery PTD may be issued and should contain 

the ID numbers of both of the registered mobile facilities 

- For the special case where title changes while a mobile component is in 

transit (but the fuel never leaves the mobile component and facility), the 

original entity that registered the mobile facility will continue to be 

responsible for the D&T requirements until the fuel leaves that mobile 

facility (i.e., a case where title is transferred “on the water”- fuel in a barge 

that is covered by one entity’s mobile facility is sold to another entity 

while the barge is in transit) 

• Violations and Liability

- D&T Violations: For D&T violations, liability is by registered facility 

(and we would consider, in cases such as this, fuel in a contracted mobile 

component to be in the custody of the registered entity since the mobile 

component and the fuel are within the ‘boundaries’ of the entity’s facility, 

and the entity still has title to the fuel) 

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◦ For example- if a volume balance error was found anywhere within 

a registered mobile facility, the registering entity would be the 

party held responsible 

- Standards violations: For standards violations, liability is by any

party/facility and can be either custody or title-based-- all parties involved 

in cases of standards violations could be presumed liable; including the 

entity that registered the mobile facility and the owner/operator of the 

mobile component in which the off-spec fuel is found 

◦ As with all fuels programs, presumptive liability may also affect 

all other parties ‘up the chain’ that handled the specific batch of 

fuel

◦ EPA may require that records regarding the specific contracted

mobile components be produced 

• Aggregation

- An entity may aggregate a mobile facility with another one of its facilities 

only if the entity owns all of the mobile components in that mobile facility 

(similar to § 80.502(b)(2)) 

- Per § 80.502(b)(4), mobile facilities may only be aggregated with a 

facility that they receive fuel from or deliver fuel to, but not both 

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