Posts Tagged ‘EPA’

Stakeholder Survey Results

To following graphs summarize the results from a recent stakeholder feedback survey.  These results are being shared with EPA in an effort to assist with proposed changes to the Renewable Fuel Standard.

Let EPA know what you think!
WEIGH IN WITH YOUR OWN OPINION

Need More Details?
Complete Details Are Available Here!

Let EPA know what you think!
WEIGH IN WITH YOUR OWN OPINION

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Introducing RFS2 Video Updates

Have a look at this short video to learn more about what we are doing at RINSTAR® to prepare for the New Advance Renewable Fuel Stanard (RFS2). You might want to also want to get a copy of “America Advances to Performance Based Fuels” White Paper in order to establish a good overall understanding of the program.

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RFS2 Workshop in Iowa

The Iowa Renewable Fuels Association is co-hosting a workshop on RFS2 along with the National Biodiesel Board, the Renewable Fuels Association, Growth Energy, and the American Coalition for Ethanol on April 6th in Des Moines Iowa. I have been invited to present on the subject of RINs and the transition to the new EMTS database. Two EPA representatives will be present, along with industry experts to answer questions about RFS2 and the transition that is currently underway.

View a copy of the agenda here:
irfa-rfs2-conference

The deadline for registration is Friday, April 2. The form is available here:
Workshop-Registration-Form

If you are in Iowa at the conference, be sure an look me up.

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Educational Series: How are RINs Tracked?

RFS Educational Series Briefing No. 5: How Are RINs Tracked?

Written by Clayton McMartin for Televent DTN

The RFS regulations require that accurate records pertaining to RIN activity be maintained and summary reports be submitted to EPA each quarter (1). In principle this is a simple concept; in practice it is much more complex.

As title to product and the associated RINs are transferred from one party to the next the supplier (transferor) is required to generate and deliver documentation to their customer (transferee). As the transferee then sells to their customer, and so on down the line, the same type of documentation is required each time title is transferred. Now that each of these events has been documented, each party is required to keep the records in an organized manner and report to EPA every quarter on their activity. These standardized reports are due two months after the quarter closes (1). EPA staff members can then process the data to track the movement of renewable fuel through the supply chain and determine if all parties are in compliance.

EPA utilizes a post-audit approach to the program, where they gather data pertaining to literally millions of transactions and then process, looking for discrepancies and inconsistencies among the data. The shortcoming of this approach is the fact that possible violations are revealed months after they have occurred, making for considerable challenges in the area of enforcement and overall exposure.

An alternative approach is for companies to voluntarily participate on the renewable fuel registry where they take a proactive approach to RIN tracking and validation. By utilizing a third party verifier, companies are able to manage massive amounts of data on one standardized computing system (2). Through a centralized registry, companies are also able to conduct a more through job of due diligence and minimize ownership issues before they occur. The RIN program is “Buyer Beware” and any liability resulting from title defects fall to the current owner.

(1)Future View: As discussed in Briefing #2, the reporting frequency will increase under RFS2, first to monthly then to within three days of the transaction.

(2)Future View: EPA has proposed a centralized and closed system for clearing RIN transactions known as the EPA Moderated Transaction System (EMTS). EPA has stated that they hope to bring increased confidence to the marketplace with EMTS – schedule to go into effect in 2011. More details will be provided about EMTS in future briefings.

Click here to download a PDF of Educational Series Briefing No 5: How are RINs Tracked?

Past briefings are available by clicking here.

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Editorial: EPA Appears Caught in a Catch 22

Two key timing issues have essentially paralyzed the Environmental Protection Agency at this point regarding the Renewable Fuels Standard. The first is the pending issuance of the much awaited final rules for RFS2 and the second is the Nov. 30th deadline for the 2010 mandates. It appears that EPA cannot issue one without the other.

Why is this? Because it is essentially a “Catch 22” leaving EPA in the unenviable position of establishing a mandate with what some will challenge they have no authority to do.

In fact, during the comment period for RFS2 notice of proposed rulemaking, the American Petroleum Institute in comments from Al Manato delivered to the docket on Sept. 25 made the following comments on this subject:

a. EPA cannot enforce EISA RFS volume mandates without final regulation.

“It is API’s position that EPA cannot lawfully establish renewable fuel standards (either general or fuel-type specific) based on the volumes set forth in the Energy Independence and Security Act of 2007 (EISA) without completing the rulemaking specified in the final sentence of CAA 211(o)(2)(A)(i). In addition, EPA cannot lawfully extend the RFS program to fuels other than gasoline. API is concerned that the Agency has imposed the EISA-mandated total renewable volume in 2009. EPA should not attempt to enforce a 17 percent greater mandate in 2010 until the RFS2 rulemaking is finalized. The rules that were finalized according to the Administrative Procedures Act procedures which implemented the Energy Policy Act of 2005 (EPACT05) require no more than 6.8 billion gallons of renewables in 2010.”

Nov. 30th came and went without EPA issuing the much awaited 2010 mandates for renewable fuels. The 2005 Energy Policy Act requires EPA to work with the Department of Energy and establish the coming year’s renewable fuel standard, which then allows obligated parties to establish their volumetric targets for the coming year. According to statutes, this report is due no later than Nov. 30th of the year prior to the compliance year in which the mandates are being established.

Of course, the mandates also serve as a floor to renewable fuel demand and allow producers, distributors, marketers, blenders, and importers to establish their strategic plans for the coming year. Even in the best of cases, there is little time to make final operational and commercial modifications. And now with less than a month remaining in 2009, companies are left wondering what the final targets will be.

Obviously, not everyone sees this important issue the same way. However, the bottom line is the fact that this constant uncertainty combined with delays will take its further toll on all who operate in the renewable fuels business arena.

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Coming Up Short

Coming Up Short

By: Kris Bevill
From the November 2009 Ethanol Producer Magazine

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As the U.S. EPA ponders comments submitted in response to its proposed rule for the second stage of the renewable fuel standard, cellulosic biofuel producers wonder how they will produce enough fuel to meet a 2010 mandate, and what will happen to the industry if they don’t.

The U.S. EPA’s proposed rule for the second stage of the renewable fuel standard (RFS2) is filled with complicated issues that address everything from indirect land use impacts to definitions of feedstocks and greenhouse gas emission reduction rates. A final rule is not expected from the EPA until at least Dec. 1 and could possibly be delayed until next year due to the complexity of the issues being addressed. Nevertheless, in its proposal, the agency calls for 2010 mandate requiring 100 million gallons of cellulosic biofuel to be produced and, so far, there is no indication the agency plans to lessen the volume requirement.

Read the rest of this entry »

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RIN Credits, Ethanol Blending and the 800-pound Gorilla

RIN Credits, Ethanol Blending and the 800-pound Gorilla

By: Ron Kotrba
From the April 2009 Ethanol Producer Magazine


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Renewable energy credit prices are on the rise as ethanol blend economics remain poor and the year-end reporting date looms. EPM talks with Clayton McMartin, president of Clean Fuels Clearinghouse, about renewable identification number credits, industry consolidation, and the oil industry’s 800-pound gorilla, Valero Energy Corp., which can no longer be ignored.

The 800-pound gorilla in the room finally announced itself in early February. For months, speculators have been trying to figure out which ethanol companies will buy out which ethanol plants during this period of crushing economic recession and potential ethanol industry consolidation. Aside from food companies, what other industry made record profits in 2008 and could logically purchase distressed ethanol production facilities? The oil refiners—they who are obligated to blend ethanol into their supplies as mandated under the federal renewable fuels standard (RFS). On Friday, Feb. 6, VeraSun Energy Corp. “took out the trash”—that’s public relations lingo for releasing bad news on a Friday, with the understanding that there will be little coverage of it until at least Monday. The same day, VeraSun issued a press release titled, “VeraSun Energy Obtains ‘Stalking Horse’ Bid From Valero for Five Facilities; Files Motion Seeking Authority to Sell Substantially All Assets by March.” Read the rest of this entry »

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EPA rolls out RINs Moderated Tracking System

EPA Rolls Out RINs Moderated Tracking System

By: Ron Kotrba
From the March 2009 Web Exclusive Ethanol Producer Magazine

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The U.S. EPA held a Webinar on Feb. 25 to explain its development of a Moderated Tracking System that will accurately and securely track renewable identification number (RIN) credits.

A RIN is a 38-character numeric code that’s generated by the producer or importer of renewable fuel; it represents gallons of renewable fuel produced/imported and is assigned to batches of renewable fuel that are transferred (change of ownership) to others. RINs are valid for the calendar-generated, or the following year.

RINs currently apply to the ethanol industry; however beginning in 2010 RINS will also apply to the biodiesel industry.

The EPA is developing MTS to track the generation, distribution and sale of RINs as a way to help accurately enforce the mandates under the renewable fuels standard enacted in the Energy Independence & Security Act of 2007. The market-based renewable fuels registry RINSTAR has been working with the EPA to help develop a federal register through which all RIN transactions would flow to ensure accurate and honest reporting. Read the rest of this entry »

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Moderated Transaction System

EPA introduced the concept of a Moderated Transaction System (MTS) on Wednesday February 25th during a webinar to an industry audience of 200 people.  The purpose of the webinar was to seek stakeholder input prior to the MTS being proposed in the Notice of Proposed Rule Making (NPRM), anticipated to be issued any day now.  The print material is provided in the two files shown here.

With support of media partners, Ethanol Producer Magazine and Biodiesel Magazine, the Clean Fuel Standards Advisory Board (CFSAB) will sponsor a replay of the orginal webinar along with an interactive series of polling and commentary.  This followup webinar is scheduled for Thursday March 5, 2009 from 1:00 - 2:30 EST.  Interested parties are invited to register for the event by selecting this link now:
https://www2.gotomeeting.com/register/495977954

Results from the polling will be shared during the webinar with all who participate.  In addition, polling results and all questions gathered througout the event will be compiled and delivered to EPA as a representative sampling of the affected industry stakeholders.  Over 540 people have already registered for the event.  There is a limited seating of 1,000.

Using CDX and the Exchange Network Services

EPA Presentation EMTS 2-25-09

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Spot Ethanol Prices Flat as Supply, Demand in Balance

Spot Ethanol Prices Flat as Supply, Demand in Balance

By: George Orwel
February 2009 DTN Refined Fuels

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NEW YORK (DTN) — Spot ethanol prices rose slightly on Friday from the levels seen Thursday, but there wasn’t much change for the week as traders weighed lower corn prices against higher gasoline values.

In fact, in the ethanol swaps market, prices came off about 3cts, driven largely by the weaker corn market. But physical cargoes of ethanol for late January to early February delivery to Chicago traded at $1.57 and $1.59 gal, reflecting a session gain of 2cts and up 1.5cts for the week.

In the New York Harbor, physical cargoes traded 3cts higher for the session and 1.5cts higher for the week. Houston prices were discussed between $1.68 and $1.70 a gal, although no trade was reported. In the West Coast, most of the discussions on cargoes going to Las Vegas and a few to Phoenix, Ariz., with just a few to California. Read the rest of this entry »

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