EcoEngineers, provider of the first and largest quality assurance program (QAP) in the renewable fuel industry, announced Feb. 22 that it is offering both the QAP options available in U.S. EPA's proposed standards.

Both options, QAP-A and QAP-B, will provide assurance that renewable identification numbers (RINs) are properly generated and offer affirmative defense for the transfer or use of invalid RINs. However, only the QAP-A option will provide for the replacement of invalid RINs. The two-tiered plan will help reduce the number of incorrectly generated RINs in distribution and provide smaller producers the same access to RIN markets that the bigger players have by making validated RINs a fungible commodity.

The two QAP options are designed to provide flexibility in how producers and obligated parties choose to manage the risk of transferring or using invalid RINs. QAP-A is more stringent, requiring ongoing monitoring of many program components and offers both civil liabilities waivers and RIN replacement; QAP-B requires less frequent monitoring and only offers a waiver from civil liabilities.  

The EPA's Notice of Proposed Rule Making, the process by which the agency establishes such standards, treats all QAP providers as equal in their ability to offer EPA incentives, including civil liability waivers and RIN replacement.

RINs can be given an “A” or “B” designation by any QAP provider who is registered with the EPA to offer that service for a particular D code and fuel pathway. Downstream parties are relieved of the burden of proving RIN validity as long as the RIN QAP provider is registered with the EPA.

“By working with producers to verify their RINs, we relieve obligated parties of worries related to the quality of those RINs,” said EcoEngineers' RIN QAP Manager, Karyn Jones. “We make it safer and easier for everyone involved in RIN creation and exchange.” With the EPA now asking for comments on the NPRM, EcoEngineers is looking into alternatives for several requirements in order to make the final rules easier on budget-conscious producers.

Shashi Menon, managing partner at EcoEngineers, advises producers and obligated parties to closely review new QAP-A and QAP-B plans as they become available to avoid high fees, unnecessary equipment, restrictive long-term contracts and vague promises. “There's a good reason why we have so many producers in our program,” said Menon. “RIN markets are automatically adjusting to the new order and accepting Eco QAP RINs at market prices. We also offer our customers a long list of additional services along with our QAP work. This ensures that their overall compliance costs stay low. And we don't force people into long-term contracts.”