RFS2 Compliance: Little Known Facts Can Have a Big Impact
by Ashley Player (Biodiesel Magazine/Frazier, Barnes & Associates) …One potential gray area is the treatment of off-spec biodiesel—many facilities simply sell the material without RINs to be reprocessed by other biodiesel plants. A question that might be asked is: does an approved pathway exist for the production of biodiesel from off-spec methyl ester, if the methyl ester originated from approved feedstock?
To answer this question, we have to go back to the fundamentals of RFS2. Everyone now knows that in order to generate a valid RIN, the fuel must have been produced according to a pathway in Table 1 to §80.1426.
…What if the plant could trace each gallon of biodiesel back to the original feedstock used to make it to ensure that it is on the list in the table above? Could valid RINs then be generated? According to EPA representatives and due diligence performed by FBA, the answer would be “no.” The reason being that a facility registers with the EPA as a “producer” and must certify each batch of fuel produced for all of the steps shown above. READ MORE
