July 19, 2012
BY Frazier Barnes & Associates
RIN fraud and RIN verification have emerged as key factors in a biodiesel plant’s viability as evidenced by the recent lawsuits for invalid RINs. As a result of a few bad apples, all advanced fuel plants are now held to a higher standard to prove that their RINs are legitimate. Because of the increasing amount of negative publicity directed at the industry, programs have emerged to assure the marketplace that RINs being traded are indeed valid. Frazier Barnes & Associates, a trusted name in the biodiesel industry for more than a decade, has launched a comprehensive RIN verification program to meet the needs of the industry. FBA has partnered with RIN Attest and Advisory Services to form RINtrust LLC, offering a unique bundle of services to ensure valid RINs.
“The RFS2 engineering review is an important factor in establishing verifiable RINs, but it is not the only factor,” said Pete Moss, president of FBA. “We have now bundled the RFS2 engineering review with the RFS2 annual attest engagement and an inventory management program that closely monitors incoming feedstock and outgoing product.”
Buyers can rest assured that the RINs associated with this program will be valid. FBA is already working with plants, blenders and obligated parties to ensure RIN integrity, manage inventory and monitor process yields.
The RIN verification program will be conducted by RINtrust LLC, a collaboration of FBA and RIN Attest and Advisory Services. Their synergistic experience in the industry provides a unique perspective on the RIN verification process that enables a biodiesel plant to produce RINs in confidence—while simultaneously gaining valuable information about process economics and yields.
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The methodology is simple: a plant cannot generate RINs from feedstock that is nonexistent or originates from an unapproved pathway. Reconciling each pound of feedstock with each pound of biodiesel, adjusted for yield and temperature, is the most effective way to ensure RIN validity.
RINtrust pledges to provide economical services that not only ensure the validity of the RINs, but also adds significant value to the biodiesel facility. The RINtrust program combines existing knowledge and services that:
-are comprehensive and user friendly
-are cost effective and add value to the company bottom line
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-provide the highest level of RIN integrity possible
-allow the biodiesel facility to operate discreetly, without exposing sensitive and proprietary information
Due to a recent change by the EPA, RFS2 engineering review updates for all renewable fuel plants registered in 2010 are due by Jan. 31, 2013.
When scheduling your RFS2 engineering review site visit, FBA can arrange the initial RINtrust assessment at no additional cost. This is an important feature of the program because the site visit for the engineering review is already required. Also required is the annual attest engagement. By combining these tasks under one umbrella, service duplication and costs can be minimized. The plant may choose to do just the engineering review, but it can be conducted in unison with the RIN verification program as an option. The RINtrust program is less cumbersome, yet very effective, as shown in Figure 1.
“Our clients have responded very positively to this program,” Moss said. “They trust our judgment, as well as our employees, many of which have been with us for over a decade. In times of volatility and uncertainty, people seek trust and experience. This program offers both.” RINtrust will turn a negative into a positive, which will make the entire industry stronger and more sustainable.