Photo: Erin Voegele, Biodiesel Magazine
February 8, 2011
BY Erin Krueger
The U.S. EPA’s renewable fuel standard (RFS2) program can be difficult to understand and navigate, particularly for biodiesel producers who are new to the program. While many of the producer requirements have been streamlined since the inception of the first stage of the RFS2 program, challenges and uncertainties still exist. A session titled RFS2 101— The Basics at the National Biodiesel Conference & Expo in Phoenix provided attendees with an overview of the program and steps they need to take to participate.
National Biodiesel Board Legislative Assistant Francisco Matiella kicked off the session by describing the differences between the first and second stages of the RFS program, including the nested volume requirements, the component parts of renewable identification numbers (RINs) and the program’s statutory definition of renewable biomass.
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Currently, 147 biomass-based diesel facilities have registered with the EPA under the RFS2 program, Matiella said. “The capacity of all these facilities is greater than 2 billion gallons,” he continued, noting that current data shows sufficient feedstock to produce 1.8 billion gallons of the fuel. While several feedstock pathways have already been approved by the EPA under the RFS2 program, those for palm oil and Canadian canola oil are still pending.
Matiella also spoke about the process biodiesel producers must go through to become registered under the RFS2 program, which includes interacting with the agency’s Central Data Exchange and the EPA’s Moderated Transaction System (EMTS).
Kansas State University professor Richard Nelson, who contracts with the NBB, also presented during the session. He spoke to attendees about the goals and intentions of EMTS. During the first stage of the RFS1 program, renewable fuel producers generated their own RINs. This led to a lot of unintentional errors, Nelson said, which was a primary motivator in the EPA’s development of the EMTS. The system actually generates the RINs for producers, essentially eliminating unintentional human error. With the added complexity of the RFS2 system, the EMTS offers a much needed streamlined approach to RIN generation.
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Nelson also spoke about the four ways that RINs generated by the EMTS system can be separated from gallons of biomass-based diesel. “[The] most common [way] is when the biodiesel is mixed with diesel or it creates a blend of B80 or less,” Nelson said. “At that point, once it’s blended, those RINs have been separated and they are ready for sale.” RINs are also separated from product when it’s sold for use as a neat product. One example offered by Nelson is underground mining companies that purchase B100 to help mitigate air quality issues. Upward delegation is the third method by which a RIN can be separated. This often happens when product is sold to small blenders who don’t want to deal with RINs. The RINs are effectively transferred back to the producer. Finally, exporters separate RINs from product when fuel is shipped overseas. In this case the RIN is retired, Nelson said.
While RFS2 101—The Basics offered a broad overview of the RFS2 program, Nelson and Matiella recommended that attendees who wish to gain more in-depth knowledge of the topic attend the conference’s more detailed RFS2 Workshop on Wednesday morning.