Authentication, not validation
I had an in-depth conversation recently, as well as various correspondences over the past few months, with Ramon Benavides—who many of you may know or at least his name rings a bell for you, as he is fairly well-known in biodiesel circles—on the topic of a new feedstock authentication program his company, Global Renewable Energy Strategies and Consulting, developed in partnership with Gorge Analytical. The result of those conversations was a story I published yesterday on BiodieselMagazine.com titled “Program launched to authenticate feedstock as ‘renewable biomass.’”
As I write in the article, it may seem common sense that fuels qualified under the renewable fuel standard must be made from renewable biomass, but Ray says proving this is not an easy task for producers. In fact, he estimates that if biodiesel producers had to prove their feedstock meets the totality of the definitions of “renewable biomass,” 90 percent of them couldn’t do it. I say totality of definitions because, as Ray reminds me, there are several statutes, codes, sections, subsections and parts to various laws of multiple government agencies—the EPA’s RFS and the Clean Air Act, the IRS and the USDA—that cross-reference and create a complex web of compliance obligations that could make anyone’s head spin. Anyone except Ray’s that is.
The program, called the Feedstock Conformance Protocol, is designed to authenticate RINs on the frontend through a rigorous feedstock testing program, using the expertise of Jeff and Michelle Fetkenhour (Gorge Analytical), rather than validating RINs on the backend.
Ray says feedstock contaminants he has seen include PCBs, ethylene glycol, sulfur, heavy metals like chromium and even motor oils. Just before publication of the article, Ray told me his program caught concentrations of contamination in feedstock that saved the purchaser about $2 million.
The program provides a feedstock profile to the producer before it arrives at the plant. Ray also says he is working with EPA, biodiesel producers, and QAP and feedstock providers, and notes that none of the QAPs on the market have this central component in their program. He also points out that the FCP is complementary to all existing QAPs, and he says it was specifically designed to not cost small producers “an arm and a leg.”
Check out the link to the story above, and let me know your thoughts on the program, and its role in authenticating biodiesel RINs via feedstock testing.