Program developed to authenticate feedstock as ‘renewable biomass’
It may be common sense that a qualified renewable fuel under RFS must be made from a renewable biomass, but Ramon M. Benavides, president of Global Renewable Strategies and Consulting LLC, says proving this isn’t as easy as it sounds. “The burden of proof lies with the producer,” he says. “The producer has the responsibility to prove their feedstock is deemed satisfactory. If producers had to prove their feedstocks meet the criteria of ‘renewable,’ 90 percent of them couldn’t do this today.” Benavides, along with Jeff and Michelle Fetkenhour of Gorge Analytical LLC, developed the Feedstock Conformance Protocol, which mitigates risk in the biodiesel marketplace by authenticating RINs on the front-end through a rigorous feedstock-testing program rather than just validating RINs on the backend. Gorge Analytical was chosen as a partner because of its strong history, knowledge and experience in the field.
“The FCP screens the feedstock to make sure there are no bad actions or contaminants that would diminish qualification of the finished fuel,” says Benavides. “When this protocol is combined with a qualified production process, objective evidence is compiled to authenticate the renewable fuel. Over time we became keenly aware that adding additional forensic methods was needed to rule out contaminants, so the only thing left over is renewable biomass and, therefore, the only fuel produced is a renewable fuel.” Some contaminants Benavides has seen in feedstock include PCBs, ethylene glycol, heavy metals such as chromium and arsenic and even motor oils.
A feedstock profile is provided before the material arrives at the biodiesel facility, which helps prequalify feedstock for RINs authentication through the combined assessment of: key markers that ensure the product purchased is the product received; adulterants that will affect mass balance criteria; the presence of select, dangerous hazardous materials that would mitigate a nonconformance with Tier 1 and Tier 2 Health data and threats to the environment; the potential for previously produced fuels sold as feedstock; as well as identifying necessary criteria to ensure authenticity of a RIN and renewable fuel by measuring required components in several codes, including EPA’s RFS, USDA’s bioenergy and biopreferred programs and the IRS’ biodiesel, renewable diesel, and alternative fuels excise tax program.
Benavides said the FCP is complementary to all existing RIN quality assurance plans. “None of them have this central component,” he says. Benavides is targeting FCP application directly to biodiesel producers, seeking partnerships with existing third-party RIN verifiers, feedstock providers and government. The FCP establishes a baseline for each producer or producer’s supplier and then transitions to scheduled interval testing to ensure for the producer that the supplier is maintaining conformance of the initial profile. During this period, the FCP randomly rotates assessment without prior notice through five components to reduce risk of fraud.