EPA rolls out RINs Moderated Tracking System

February 4, 2009

BY Ron Kotrba

Web exclusive posted March 4, 2009, at 9:46 a.m. CST

The U.S. EPA held a Webinar on Feb. 25 to explain its development of a Moderated Tracking System that will accurately and securely track renewable identification number (RIN) credits.

A RIN is a 38-character numeric code that's generated by the producer or importer of renewable fuel; it represents gallons of renewable fuel produced/imported and is assigned to batches of renewable fuel that are transferred (change of ownership) to others. RINs are valid for the calendar-generated, or the following year.

RINs currently apply to the ethanol industry; however beginning in 2010 RINS will also apply to the biodiesel industry.

The EPA is developing MTS to track the generation, distribution and sale of RINs as a way to help accurately enforce the mandates under the renewable fuels standard enacted in the Energy Independence & Security Act of 2007. The market-based renewable fuels registry RINSTAR has been working with the EPA to help develop a federal register through which all RIN transactions would flow to ensure accurate and honest reporting.

The EPA has determined that there is a need to moderate RIN transactions because there is a large volume of invalid RINs on the marketplace. In 15 months' time there were 27,000 rejected, invalid RINs, according to Clayton McMartin, president of Clean Fuels Clearinghouse and RINSTAR. "During that time, we have safeguarded our membership from hundreds of millions of invalid Gal-RINs," McMartin said. The EPA stated it won't play "matchmaker" in the market with RINs, but instead will act as an accounting mechanism to bring integrity to the market.

McMartin made an analogy between the federal banking system and MTS. When a check is cashed at a bank, unless the check is from the same bank it's being cashed at, it takes a couple of days for the check to clear while it's verified through the federal bank register. This is similar to how a federal RIN registry would work. While optimum circumstances would allow for "real-time" verification there will likely be a lag time of a few days. However, compared to the system now, where once a quarter the EPA receives RIN reports and post-auditing, there is a semblance of real-time to the MTS.

The MTS won't be enacted until the final RFS2 rule comes out, which isn't expected until Jan. 1, 2010, at the earliest. First there must be a proposed ruling set forth, followed by a comment period; after consideration of the comments a drafting and announcement of the final rule will be made. But when it does activate, EPA will no longer accept spreadsheets or RINs incorporated in invoices as a means to report RIN transactions.

There were some audio difficulties throughout the Webinar, which may result in a rebroadcast.

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