White Paper on EPA's Proposed RFS/RIN Biofuel Program Changes

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This Stoel Rives white paper provides a comprehensive overview of proposed regulatory changes to the Renewable Fuel Standard ("RFS") program, specifically the renewable identification number ("RIN") market. The U.S. Environmental Protection Agency ("EPA") initiated these proposed changes following its revelation that several individuals and companies had fraudulently issued millions of invalid RINs. This white paper is intended as background for those who need to plan for compliance now and those who may want to submit testimony or comments during the rule's comment period scheduled to open March 19, 2013.

Specifically, the white paper reviews how the EPA's proposed quality assurance plans ("QAP") rule seeks to leverage and refine third-party verification systems, improve RIN market liquidity and provide greater assurance that the RFS program will meets its volumetric goals. The paper describes how the proposed rule introduces a means for obligated parties to assert an affirmative defense where RINs are found to have been invalidly generated, establishes third-party RIN auditors and promotes tagging of verified RINs in order to demonstrate verification downstream. Differences between the rule's QAP Option A and QAP Option B are also highlighted.

Key Contributors

Sara E. Bergan
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