Fortifying the RPS EPA s Proposed RIN Quality Assurance Program

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1 Fortifying the RPS EPA s Proposed RIN Quality Assurance Program Authored by Graham Noyes and Sara E. Bergan White Paper

2 TABLE OF CONTENTS Page Authors' Note... 1 I. Introduction... 2 II. Primary Objectives of Rulemaking... 4 III. Establishment of a Quality Assurance Program... 5 A. Requirements for an Affirmative Defense... 7 B. RIN Replacement... 9 C. Treatment of Interim RINs...10 D. Basic Differences Between the Two QAP Options...11 IV. Other Issues Raised by the NPRM...12 A. Auditor Qualifications...12 B. Tracking Verified RINS...13 C. RIN Separation...14 D. Downstream Validity...14 E. Exported Fuels Clarification...15 V. Conclusion...16 Appendix A: Tables Appendix B: Author Profiles i

3 A u t h o r s ' N o t e Attorneys from Stoel Rives LLP have represented a wide range of biofuel and petroleum industry clients since the advent of the U.S. ethanol industry. In the past decade, the Renewable Fuel Standard (the RFS) has emerged as the key policy driver supporting the growth of both first generation and advanced biofuels. Stoel attorneys have been actively involved in reviewing RFS compliance issues, developing contractual provisions informed by RFS requirements, assisting clients facing RFS enforcement actions, representing clients in RIN contract disputes, and communicating and negotiating with EPA officials on crucial issues of RFS interpretation. The following white paper provides an overview of the Environmental Protection Agency s recently proposed amendments to the RFS program. This white paper is provided as a general summary to the program changes and should not be relied upon as definitive legal advice. Graham Noyes Sara E. Bergan 1

4 I. INTRODUCTION The year 2012 will be remembered by participants in the U.S. transportation fuel industry as a period of risk and volatility in the RIN market. RINs (renewable identification numbers) are credits under the federal Renewable Fuel Standard (RFS). The RIN market is an active and complex credit market, with the value of RINs generated in 2012 exceeding $1 billion. The RIN market was originally created by Congress with the passage of the Energy Policy Act of 2005, which established the first RFS. Congress added more complexity to the RIN market when it expanded the RFS through the Energy Independence and Security Act of 2007 and created what is sometimes referred to as RFS2. Under the RFS and RFS2, RINs are credits that obligated parties (petroleum refiners and importers) must acquire to prove compliance with fuel mandates for specified categories of renewable fuel. The RIN categories are based on the reduction in greenhouse gas (GHG) emissions that each biofuel provides on a lifecycle basis as compared to petroleum fuels. Congress vested the Environmental Protection Agency (EPA) with extensive authority to develop the regulations for the RFS, and tasked the agency with interpreting and enforcing those regulations. The risks inherent in the RIN marketplace were starkly revealed in the third quarter of On October 3, 2011, the United States Attorney for the District of Maryland filed a criminal information against Clean Green Fuel, LLC and related parties alleging fraudulent generation of over 32 million RINs. Consistent with the RFS2 regulatory system of strict liability, the EPA subsequently served 24 notices of violation on obligated parties for use of the Clean Green RINs to fulfill renewable volume obligations (RVOs). By the end of April, the EPA had revealed allegations that Absolute Fuels and Green Diesel had also generated invalid RINs that had been widely traded in the RIN marketplace. All together, the EPA alleged that the three companies had generated over 140 million biomass-based diesel RINs that did not represent qualifying biofuel. 1 The invalid RINs from these three companies represented approximately 13 percent of the nationwide biodiesel volume in 2010 and 4 percent in

5 In February 2013, Rodney R. Hailey of Clean Green Fuel, LLC was sentenced to more than 12 years in prison for selling RINs invalidly produced by his company. 3 The sentencing followed his June 25, 2012 conviction by a trial jury of eight counts of wire fraud, 32 counts of money laundering and two counts of Clean Air Act violations. 4 In its recent statement on the matter, the EPA noted that Hailey s fraud not only led to a loss of more than $40 million to traders and major energy companies, but also extended to small bio-diesel companies, many of which, as a result of Hailey s scheme, were unable to sell their RINs and have been forced out of business. 5 Under the buyer beware approach, regulated parties that transferred or used such invalid RINs were in violation of the RFS rules and subject to civil penalties. The obligated parties in these cases generally had to find valid replacement RINs to fulfill their RVOs and enter into settlement agreements to resolve their civil liabilities. While it was the obligated parties that received Notice of Violations (NOVs) from the EPA, middle market companies likely shouldered the heaviest financial burden from the fraudulent RIN schemes. These companies were often caught in the middle between downstream parties who could turn to contractual provisions to obtain RIN replacements, and upstream RIN sources and suppliers who were financially unable to supply replacement RINs. In the wake of the invalid RIN revelations, the EPA released an interim enforcement response policy (IERP) on March 14, This policy applied only to 2010 and 2011 invalid RINs and provided only limited direction to interested parties. Throughout 2012, EPA officials conducted more than a hundred meetings with various market participants and received substantial feedback on how to improve the RFS program as it related to invalid RINs. On January 31, 2013, the EPA simultaneously released a second IERP (IERP2) and a Notice of Proposed Rulemaking (NPRM) on the RFS Renewable Identification Number Quality Assurance Program. The IERP2 and NPRM are best understood as representing the EPA s articulated plan to respond to the problem of invalid RINs in the marketplace in a manner that is informed by diverse industry input. Taken together, the two policy documents represent a substantial evolution of the RFS program. A public hearing will be held on March 19, 2013, in Washington, D.C., followed by a 30-day comment period. Given the importance of the issue, there is likely to be significant input during the comment 3

6 period, and market participants will be well-served to ensure that they understand the proposals and provide input to the process. Under Clean Air Act jurisprudence, the failure to raise a challenge to a regulation during the rulemaking process will often preclude a later challenge to the provision, including in enforcement matters. II. PRIMARY OBJECTIVES OF RULEMAKING In the NPRM, the EPA explains that the alternative mechanisms presented for ensuring that RINs are appropriately generated are an attempt to address the inefficiencies that have arisen in the RIN market. 6 Under current law, obligated parties must demonstrate fulfillment of their RVOs with valid RINs. The use of invalid RINs to meet the obligations knowingly or unknowingly is a prohibited act that subjects the party to civil liability. This buyer beware approach was intended to encourage market participants to self-police to avoid exposure to liability. EPA s recent enforcement actions suggest that the buyer-beware approach was insufficient to prevent significant numbers of invalid RINs from entering the marketplace. In response to the invalid RIN revelations, obligated parties began taking actions to minimize risk exposure. These responses were driven by economic circumstances and sometimes included shifting away from lesser known, smaller volume producers, treating them as higher-risk and less worthy of due diligence reviews. 7 As a result, smaller biodiesel producers were sometimes forced to offer their RINs at a significant discount relative to RINs from larger, more established producers whose higher volumes and larger balance sheets were more attractive to obligated parties. 8 Although the EPA noted that the buyer-beware approach to credits has proven effective with previous mobile-source fuel programs, the agency determined that, in the case of the RIN market, it has not caused regulated parties to conduct proper oversight and has had unintended consequences for smaller producers. The agency s proposed quality assurance plans (QAP) rule is an effort to devise additional regulatory provisions that could provide greater confidence in the validity of the RIN market without restricting small-producer access to the market. 9 By creating a set of voluntary regulatory provisions, the EPA hopes to leverage and refine third-party verification systems, improve RIN market liquidity, and provide greater assurance that 4

7 the RFS program will ultimately meet its volumetric goals. The EPA explains further in the NPRM: These provisions are intended to reduce the incidence of invalidly generated RINs entering the market, provide reasonable assurance of replacement of invalidly generated RINs, and increase liquidity in the RIN market. The proposed QAP provisions would serve as the major component for an affirmative defense against liability in the event that a party transferred or used invalidly generated RINs. With greater confidence in both the validity of RINs and protection against civil liability that an affirmative defense affords, there may be less of a disparity in value between RINs generated by large and small renewable fuel producers. As a result, there may be renewed market liquidity and certainty. [10] Ironically, the recent incidents of invalid RINs in the marketplace may ultimately serve to strengthen the RFS market and improve the RFS program. Under the original RFS2 system, the EPA refused to provide a verification method and instead required market participants to self-police. Accountability under the regulatory system fell to the obligated party. As illustrated by the Clean Green NOVs, an obligated party that used invalid RINs to fulfill its RVO could then be held accountable by EPA. This system prevented RINs from performing as fungible credits. Instead, each RIN was unique, its pedigree subject to scrutiny. This variability restricted the liquidity of the RINs, particularly when significant validity concerns surfaced. The lack of liquidity made it difficult to trade RINs or to develop any derivative product relating to RINs on market exchanges. The lack of public markets for RINs, in turn, precluded the establishment of a futures market in RINs. As discussed in subsequent sections, the proposed revisions to the RFS to make RINs more fungible and liquid may ultimately serve as the foundation for more robust RIN trading and a more effective RFS program. 5

8 III. ESTABLISHMENT OF A QUALITY ASSURANCE PROGRAM The EPA held meetings with representatives of the many industries that participate in the U.S. transportation fuels market. These industries include small to large biofuel companies that generate RINs, petroleum companies and commodity traders that aggregate and trade RINs, and petroleum refiners and importers that utilize RINs for compliance purposes. Although these groups hold divergent views on many aspects of the RFS program, virtually all emphasized to EPA the importance of reinforcing the program s integrity and establishing practical methods to ascertain the validity of RINs. In the NPRM, EPA integrated these requests into the establishment of a rigorous system to verify RINs. In order to accomplish the goals stated above, the EPA proposes to maintain the underlying buyer-beware approach but also create two alternate tracks that establish minimum requirements for RIN quality assurance and provide the basis for an affirmative defense if those RINs are found to have been invalidly generated. The two new compliance options to the RFS program each contain provisions for a QAP created by independent third parties and used to verify RIN generation. The requirements under Option A are more detailed and involved but, in the case of invalid RINs, provide for a stronger affirmative defense against liability and put the responsibility for valid RIN replacement in the hands of the third-party auditor. The requirements under Option B are less stringent, providing an affirmative defense in the case of invalid RINs but leaving the replacement responsibility in the hands of the obligated party. Along with the underlying and existing buyer-beware approach, the proposed program sets forth three options from which obligated parties can choose according to their risk tolerance. These provisions also apply to RINs generated for foreign-produced renewable fuel so long as the associated foreign renewable fuel production facility is audited under an EPA-approved QAP. The proposed system is expressly voluntary, but EPA expects that most RINs purchased and used for compliance purposes will be QAP-verified because most obligated parties will prefer not to take on the risk of using an unverified RIN. If an auditor chooses to participate in the voluntary program, it would register with and seek approval from EPA for its Option A or Option B QAP. Upon approval, the auditor 6

9 must verify RINs in accordance with the requirements of the EPA-approved QAP. Generators choosing to have their RINs verified will need to ensure that the auditor has access to the information necessary to implement the QAP. A. Requirements for an Affirmative Defense Black letter law usually describes an affirmative defense as a yes but defense. The classic example is the affirmative defense of self-defense in the law of homicide. While deliberately killing a human being is sufficient grounds to prove the crime of murder, an accused defendant may assert the affirmative defense of selfdefense. In such a case, the defense responds to the prosecutor s case by presenting evidence that yes the defendant killed the deceased but the defendant had a valid claim of self-defense. The procedure and the burden of proof for establishing this affirmative defense vary based on state law, but if self-defense is successfully proven, the defendant may be exonerated. Similarly, under other Clean Air Act provisions such as the Diesel Fuel Sulfur Control regulations (40 CFR (a)) and the Reformulated Gasoline regulations (40 CFR 80.79(b)(1)), affirmative defenses have been established to temper the sometimes harsh results of strict liability. For instance, there is a recognized affirmative defense under the regulations that prohibit the supply of leaded gasoline. To enforce the transition to unleaded fuel, Congress empowered the EPA to hold upstream petroleum companies vicariously liable for the supply of leaded gasoline by branded retailers without the need for a showing that the petroleum company actually supplied the leaded fuel. However, in such cases, the defendant petroleum company could establish an affirmative defense by showing it had not provided the leaded fuel to the station and also had taken sufficient measures to educate the retailer and to prevent the leaded fuel from being introduced. Under the proposed RFS regulations, the obligated party would similarly have the opportunity to present an affirmative defense by making a sufficient showing of preventative action. Under Option A, a party would have to prove five elements by a preponderance of the evidence to avail itself of the affirmative defense. Under Option B, an additional sixth element would have to be established. A party that successfully proves these elements, other than the generator of an invalid RIN, may 7

10 avoid civil liability for an otherwise prohibited act involving the transfer or use of invalid RINs. A party seeking to establish the affirmative defense under the RFS rules would have to do the following: 1. Demonstrate that the invalidly generated RINs were verified by an independent third-party auditor with an EPA-approved QAP; invalidity; 2. Show that it did not know or have reason to know of the 3. Inform the EPA within the next business day after identifying RINs that were invalidly generated; question; 4. Demonstrate that it did not cause the invalidity of the RINs in 5. Show that it did not have any financial interest in the company that generated the invalid RINs; and 6. Demonstrate that if the invalid RIN was used for compliance purposes, the party adjusted its records, reports, and compliance calculations appropriately (Option B only). One aspect of the second element differs between Options A and B. In the case of Option A RINs, the owner must not have had knowledge of the invalidity prior to the RIN being verified. In the case of Option B RINs, the owner must not have had knowledge of the invalidity at any time up to and including the time the RIN was transferred or used for compliance, unless the RIN generator had implemented a remedial action under the regulations. The EPA determined that the benefits in terms of market liquidity justified allowing for an affirmative defense under Option A even if the obligated party knew of the invalidity at the time of transfer. This allowance was not extended to obligated parties under Option B, where the obligated party also retains the responsibility to replace the invalid RINs. In all cases, each element would need to be proven by a preponderance of the evidence. A first step in establishing an affirmative defense would be submitting to the agency a written report along with supporting documentation detailing how the 8

11 elements were met. The report would be required within 30 days of discovery of invalid RINs. B. RIN Replacement Assurance that the renewable volume obligations are being met each year is a key component of the RFS program. Obligated parties can demonstrate RVO compliance through the ownership and retirement of a sufficient quantity of valid RINs. A system that requires replacement of invalid RINs with valid RINs is therefore essential to the program s goals. Under the proposed system, the responsibility for replacing invalid RINs differs between Option A and Option B. Under either option the initial responsibility lies with the RIN generator responsible for the invalid RINs. In the event the generator involved does not replace those RINs, however, obligated parties with Option B RINs are required to replace them, whereas obligated parties with Option A RINs are not. In either case, the replacement must occur within a specified time period after notification from EPA that the RIN generator failed to replace the invalid RINs. Under Option A, the ultimate responsibility to replace the invalid RINs with valid RINs lies with the third-party auditor. The EPA chose to do this in order to give obligated parties the greatest amount of incentive to buy RINs from smaller producers. 11 Auditors using Option A to verify RINs must maintain a replacement mechanism capable of replacing a minimum percentage of the A-RINs they verify. 12 This is due to the agency s concern that an auditor may not have the necessary financial resources to replace invalid RINs. The EPA has not specified what type of mechanism would be acceptable; rather, the agency states that the mechanism must be capable of fulfilling the auditor s potential replacement requirement for invalid RINs audited under the Option A QAP in a given calendar year and the previous four years. The NPRM does explore three potential mechanisms, including traditional financial assurance mechanisms, RIN banks, and RIN escrow accounts. The NPRM solicits input on the appropriate mechanism, and addresses the attributes and deficiencies of traditional instruments, RIN banks, and escrow accounts. To make the Option A program implementation more feasible, the EPA set a replacement cap under Option A in order to balance the benefits of encouraging 9

12 early implementation of the more robust QAP A program with the cost of early implementation. 13 For RINs generated in 2013 to 2015, the auditor s replacement responsibility under Option A would be capped at 2% of up to the last five years of A-RINs verified by the auditor. 14 The agency anticipates that the cap may change for 2016 and beyond in the final rule. The replacement mechanisms would be required to be renewed annually. Conversely, under Option B, the obligated party or RIN holder is required to replace invalid RINs not replaced by the RIN generator. The EPA does not require a RIN replacement mechanism in this instance because the agency assumes obligated parties hold major capital assets and are capable of fulfilling RIN replacement obligations. 15 However, the EPA proposes to give obligated parties under Option B a temporary limited exemption for their replacement obligations in 2013 and In order to keep the 2 percent maximum intact, the limited exemption would apply separately to each of the four fuel categories under the RFS program: cellulosic biofuel, biomass-based diesel, advanced biofuel, and total renewable fuel. In either option, the RINs replaced must be not only the same D-code, but also the same QAP category. If, for example, biomass-based diesel RINs were found to be invalid after being verified under Option A, the RINs replaced would have to have a D- code of 4 and be verified under Option A. Unverified or Option B RINs even of the same D-code would not be suitable replacements. The EPA chose to do this in part to account for different values that the market will likely place on the RINs verified under the different verification processes. The EPA has also set forth an administrative process to follow under either option in order to replace invalid RINs. Failure to implement the process could trigger an EPA enforcement action against any or all of the parties required to replace the RINs. Under Option A, for example, this would include the generator of the invalid RINs and the third-party auditor but not the obligated party. C. Treatment of Interim RINs EPA went to great lengths in this proposed rule to ensure that the QAPs are implemented as quickly as possible in the RIN market. While the broader program would become effective upon the publication of a final rule, the EPA made clear that 10

13 the proposed provisions relating to an affirmative defense would apply to RIN generation from January 1, 2013 onward. In part, EPA proposes to review auditors registration information and proposed QAPs and provide guidance on whether the plans appear to satisfy the proposed requirements before any final rule is passed as a pre-registration process. Parties will have to wait until the final rule is published for EPA to be able to actually verify QAPs, but the agency has noted that the provisions and requirements proposed in the NPRM would apply to RINs prior to the final rule promulgation, and then any changes would apply to RINs only after the final rule takes effect. In addition, EPA proposes allowing auditors to verify RINs generated before the date the audit is completed. This retrospective RIN verification process would only be available prior to a final rule. Auditors could only do this if all of the elements of the QAP were already in place and would only be able to retrospectively audit any given producer once. The EPA Moderated Transaction System (EMTS) will not be able to display RIN verification information until after the rule is finalized. D. Basic Differences Between the Two QAP Options To illustrate the differences between QAP Option A and QAP Option B, we developed two tables based on the tables provided by the EPA in the NPRM. Table I provides a broad overview of the differences between the two newly proposed voluntary programs. Table II describes specific RIN audit requirements under the two options. As noted earlier, the QAP requirements under Option A are intended to be more comprehensive because obligated parties would not be expected to oversee the auditor process. Both tables are listed in Appendix A. Each QAP must identify the specific RIN-generating pathway that it is designed to audit and include a list of elements the auditor will check in the verification process. Each auditor will submit a plan it believes is sufficient to verify the validity of the RINs; the EPA proposes the required elements of such a plan as listed in Table II. The auditor then shows how it will accomplish each element in its specific QAP. While a unique QAP is required for each pathway, a given QAP can be used for multiple facilities for which the pathway applies. The EPA would like to see the QAPs 11

14 submitted for approval every year. Further, if a producer changes feedstocks or production processes, a new QAP may be required. One primary difference between the two options is that under Option A, the EPA has proposed ongoing monitoring for several of the elements. Under Option B, by contrast, the EPA assumes that because obligated parties will hold ultimate replacement responsibility, the companies will conduct more oversight and thus all elements are evaluated on a quarterly basis. In addition there are fewer oversight elements under Option B. In all cases, the EPA has outlined specific audit requirements and expectations. These include document review and monitoring direction, instruction regarding ongoing communication with sellers and buyers in order to verify sales and purchases accordingly, and detailed guidelines as to what should happen at the onsite visit. Third-party auditors would be allowed to start verifying RINs only after the onsite audit, making the audit prospective and focused on future production. In order to facilitate at least quarterly monitoring, the EPA has proposed to allow auditors to verify RINs until the next audit is complete, but no longer than 100 days after the completion of the last audit. 16 Table II in Appendix A describes the requirements in additional detail. IV. OTHER ISSUES RAISED BY THE NPRM While not a comprehensive review, we note the following additional aspects of the proposed rule as particularly noteworthy. A. Auditor Qualifications All potential third-party auditors must register with the EPA. In so doing, the auditors would become regulated parties under the RFS program and subject to registration, recordkeeping, and reporting requirements. In addition, eligibility to be a third-party auditor involves three key criteria. First, the auditor must be independent of the renewable fuel producers being audited. The existing RFS and RFS2 rules already contain a definition of independent third-party auditors that the agency chose to keep for the current purposes. Second, the auditor must be professionally qualified to audit the facility meaning each auditor must undergo an 12

15 engineering review by a licensed professional engineer as part of the registration. The EPA notes that the effectiveness of the entire program being proposed hinges on third-party auditors ability to implement the QAPs. Third, the auditor would need to carry sufficient errors-and-omissions insurance. In addition, Option A auditors would need to demonstrate that they had suitable RIN replacement mechanisms in place. Auditors will also establish a relationship in Central Data Exchange (CDX) with the renewable fuel producer or importer. EPA will only recognize a relationship between a producer and an EPA-approved registered auditor. Because auditors may be in the best position to recognize the generation of invalid RINs, the auditor will also have the capacity to stop verification of newly generated RINs. The auditors have RIN-replacement liability under Option A, creating further incentive to stop invalid RIN generation. The EPA hopes that aligning incentives in such a manner will further reduce the prevalence of invalid RINs in the marketplace and ensure greater quality assurance. The EPA will likely require outside-certified CPAs or auditors to review underlying records, reported items, and transactions and issue reports as to their findings. Such attest engagements are similar to what other regulated parties undergo and would also be required of third-party auditors annually. 17 As mentioned above, third-party auditors engaging in the new verification program would, in turn, become regulated entities under the RFS2 program. EPA proposes to prohibit such auditors from engaging in the following acts: failing to properly implement an EPA-approved QAP, failing to timely notify RIN generators and EPA of potentially invalid RINs, failing to replace invalid RINs, and verifying RINs that are invalid. Auditors could also be liable for failing to comply with separate requirements, such as the program s registration, reporting, and recordkeeping requirements. B. Tracking Verified RINS EPA proposes to tag verified RINs in EMTS in order to demonstrate the verification downstream. A third-party auditor could only verify RINs after it had audited a facility in accordance with an approved QAP. The audit, however, would be focused on forthcoming RIN generation or prospective in nature. 13

16 C. RIN Separation Under the current rules, a renewable fuel producer can separate RINs from the associated volumes of renewable fuel in specific instances, including when the fuel has been designated and used for a conforming use. 18 As revealed by EPA s investigations, this provision was sometimes misused to sell fraudulent RINs into the marketplace without the underlying volumes of fuel. As a result, the EPA is seeking comment on whether it should remove the ability for producers to separate RINs altogether. This issue is of particular concern to biofuel producers that validly supply qualifying biofuel directly to qualifying users, such as high blend farming, transportation, or heating oil applications. In addition, the EPA is seeking comment on other options to deter invalid RIN separation that would avoid the need to invalidate RINs downstream. One such option is to change the regulations to allow obligated parties to use improperly separated RINs for compliance purposes but to make the improper separation a prohibited act. Another option is to require more information so that the EPA and obligated parties can more readily verify whether the RINs were properly separated. Yet another proposal is to require RIN separators to include information on qualifying separation events with quarterly reports. D. Downstream Validity Under current regulations, RINs may not be generated for fuel that ultimately is not designated or intended for use as transportation fuel, heating oil, or jet fuel. 19 This provision has caused problems for transactions involving properly generated RINs that later become invalid as a result of downstream activities that occur after the fuel has left the custody of the producer or importer. The EPA is considering rule amendments to mitigate this problem. As a preliminary matter, the EPA proposes to require all renewable fuel producers and importers to designate all RIN-generating renewable fuel as transportation fuel, heating oil, or jet fuel on the product transfer documents that accompany a shipment. Moreover, EPA is proposing a set of actions specific to different fuels produced that, if taken, would allow RINs to remain valid regardless of 14

17 final downstream use. The actions required reflect EPA s assessment of how likely it is for a fuel to be used for a non-qualifying use downstream. The agency, for example, believes the chances that denatured ethanol and Grade No. 1-D or 2-D renewable diesel would be used for non-qualifying end uses are very low. Thus the agency simply proposes that validly generated RINs for these fuels remain valid regardless of downstream use. For all other fuels, the agency proposes to limit RIN generation to the situation where the producer or importer has taken specific actions to ensure that the fuel is used in a qualifying use. Such actions may include additional registration information describing blending activities or, in the case of sales to third parties, additional information to verify that the fuel was blended for a qualifying purpose. If such actions are taken, the RINs generated will also remain valid regardless of final use. Under the proposed rules, parties that redesignate such fuels for a nonqualifying use would be required to retire an appropriate number of RINs. The EPA explains that this change would then place the burden of ensuring an appropriate number of RINs are retired on a party in the fuel distribution business, rather than an end user. 20 The proposed changes require retirement of the appropriate number of RINs within a 10-day period. E. Exported Fuels Clarification The EPA proposes to clarify certain aspects of the RFS program that appear to be misunderstood. One such provision is exporter RVO requirements. The EPA intends to make clear that any volume of renewable fuel that is exported requires calculation of an export RVO. The current regulations state that such calculations are required by any party that owns and exports renewable fuel in its neat form or blended with gasoline or diesel. 21 With increasing renewable fuel trade across borders, the EPA is concerned that exported volumes not be mistakenly applied toward the domestic volume requirements. EPA is also proposing to shorten the window allowed for the retirement of RINs as a result of the renewable fuel export. The time period to demonstrate compliance under the current system is essentially annual, and EPA is considering a quarterly approach. 15

18 V. CONCLUSION At the urging of industry, the EPA has proposed a substantial reworking of the RFS provisions to fortify the integrity of the RIN market. If successful, these changes could stabilize the RIN market and further the RFS program goals of energy security, reduced GHG emissions, and an expanded domestic biofuels industry. Longer term, these revisions could further the development of a futures market in RINs that would better enable advanced biofuel companies to leverage the future value of RINs to be generated by proposed facilities. Such a development could enhance financing opportunities for proposed plants and thus dramatically increase the likelihood that the U.S. will develop the capacity to produce the 21 billion gallons of advanced biofuels annually that RFS2 requires by The comment period for EPA s proposed rule will close in mid-april. Given the sweeping nature of the proposed changes, we hope this analysis provides a useful overview of the rule changes to market participants. For those companies and industry groups directly impacted by the changes, we and other Stoel Rives attorneys will be happy to provide further analysis and assist in the development of rulemaking comments and other input to the EPA. 1 RFS Renewable Identification Number (RIN) Quality Assurance Program, Proposed Rule, EPA-HQ-OAR (January 31, 2012) at Id. 3 Stacy Kika, Rodney Hailey Sentenced to More than 12 Years in Prison for Selling $9 Million in Fraudulent Renewable Fuel Credits/Owner of Clean Green Fuel falsely claimed his company produced 23 million gallons of renewable fuel, EPA News Releases from Headquarters, February 22, 2013, !opendocument. 4 Id. 5 Id. 6 RFS Renewable Identification Number (RIN) Quality Assurance Program, Proposed Rule, EPA-HQ-OAR (January 31, 2012) at Id. at Id. 9 Id. 10 Id. at Id. at Id. at Id. at

19 14 Id. at Id. at Id. at Id. at CFR (b)(4) CFR (c). 20 RFS Renewable Identification Number (RIN) Quality Assurance Program, Proposed Rule, EPA-HQ-OAR (January 31, 2012) at CFR (a). 22 Clean Air Act 211(o)(2)(B)(i), calling for 36 billion gallons of renewable fuel, of which 21 billion gallons must be advanced biofuel. 17

20 APPENDIX A Table I: Summary of Proposed QAP Options (Table III.G-1 in NOPR) Key Element QAP Option A QAP Option B Parties responsible for replacement of invalidly Third-party auditor Obligated party generated RINs Requirement for a RIN replacement mechanism as condition of registration Yes No Affirmative defense to civil liability for transfer or use of invalidly generated RINs Treatment of a knowing transfer or use of invalidly generated RINs Limited exemption for invalidly generated RIN replacement Cap on RIN replacement Requirements for QAPs Yes Affirmative defense requires the party did not know or have reason to know the RIN had been invalidly generated before the RIN was verified None For , 2 percent of the most recent five years worth of verified RINs Detailed requirements including ongoing monitoring Yes Affirmative defense requires the party did not know or have reason to know the RIN had been invalidly generated at the time it was transferred or used for compliance For , up to 2 percent of the obligated party's RVOs None Less-detailed requirements Table II: RIN Audit Requirements* (Summary of Related Tables in NOPR) Option A: QAP Option B: QAP Feedstock Ongoing Feedstock Component Monitoring (Option A) Component 1 Feedstocks are renewable biomass X 1 Feedstocks are renewable biomass 2 Separation plan for food/yard waste Separation plan for food/yard waste 2 submitted & accepted submitted & accepted 3 Separation plan for MSW submitted & Separation plan for MSW submitted and 3 accepted accepted 4 Feedstocks meet separation plan X 4 Feedstocks meet separation plan 5 Crop, crop residue feedstocks meet land use Crop, crop residue feedstocks meet land use X 5 restrictions restrictions 6 Feedstocks with additional recordkeeping X 7 Contracts for feedstocks compare to production 8 Feedstock processing, storage equipment match engineering review 9 Accuracy of feedstock energy calculation 6 Accuracy of feedstock energy calculation 10 Feedstock valid for D code, consistent with Feedstock valid for D code, consistent with X 7 EMTS EMTS 11 Feedstock consistent w/ production process X 12 Feedstock is not renewable fuel where RINs Feedstock is not renewable fuel where RINs X 8 generated generated Appendix A - 1

21 APPENDIX A Table II: RIN Audit Requirements* Option A: QAP Option B: QAP Production Process Ongoing Production Process Component Monitoring (Option A) 1 Mass and energy balances 1 Mass and energy balances appropriate 2 Workforce size 3 Process-related factors used in feedstock Accuracy of process-related factors used in 2 energy calculation feedstock energy (FE) calculation 4 Production process consistent w/ EMTS X 3 Production process consistent w/ EMTS 5 Production process consistent w/ D-code X 4 Production process consistent w/ D-code 6 Certificates of analysis verify fuel X 7 Verify existence of quality process controls 8 Volume production consistent w/other required reports 9 Volume production consistent w/ storage & distribution capacity 10 Volume production capacity consistent w/ registration RIN Generation Ongoing RIN Generation Component Monitoring (Option A) 1 Renewable fuel sold for qualifying uses X 1 Renewable fuel sold for qualifying uses 2 Standardization of volumes X 2 Certificate of analysis 3 Renewable fuel matches D-code or petition X 3 Renewable fuel matches D-code or petition 4 RIN generation consistent with wet gallons X 5 Fuel shipments consistent with production X 6 Renewable content R is accurate X 4 Renewable content R is accurate 7 Registration, reporting, recordkeeping 5 Volume production capacity is consistent with registration 8 Equivalence value EV is accurate, appropriate X 6 Equivalence value EV is accurate, appropriate 9 RIN generation calculations X 7 RIN generation calculations RIN Separation Related Ongoing RIN Separation Related Component Monitoring (Option A) 1 Verify RIN separation X 1 Verify RIN separation 2 Exported fuel not used to generate RINs X 2 Exported fuel not used to generate RINs 3 Verify accuracy of annual attestations 3 Verify accuracy of annual attestations * Quarterly monitoring is assumed for all components not subject to ongoing monitoring. Appendix A - 2

22 APPENDIX B AUTHOR PROFILES Appendix B - 1

23 G r a h a m N o y e s Experience Graham Noyes is a partner in the Stoel Rives Energy Development practice group. Due to his background in the biofuel industry, Graham dedicates a significant amount of his practice to matters related to fuel regulatory work including the Renewable Fuel Standard (RFS), the Fuel and Fuel Additive Registration program (FFARs), and other EPA administered fuel regulatory programs. Graham represents clients commercializing new biofuels, complying with FFARs requirements, developing RFS compliance and monetization strategies, participating in EPA rulemakings, and responding to notices of violation and requests for information under section 114 of the Clean Air Act. Graham joined Stoel Rives after working for seven years in the biofuels industry. He first entered the biodiesel industry during its pre-commercial phase in 2000 and went on to lead sales and business development for a biodiesel company with annual sales revenue well in excess of $100 million. During this period, he served as an advocate for the biodiesel industry in the South Coast Air Quality Management District (SCAQMD), California Air Resource Board (CARB), California Energy Commission (CEC) and other state and federal proceedings, and was elected Secretary of the National Biodiesel Board. Graham was involved with the biodiesel industry's fulfillment of FFARS and the development of a biodiesel specification through ASTM International. He also developed an understanding of the requirements and commercial value of the RFS under the original provisions of the program. When Congress revised the program with the Energy Independence and Security Act of 2007 (EISA), Graham immersed himself in the new program, typically referred to as RFS2. Professional Honors and Activities Named one of the "Top 100 People in Bioenergy for " by Biofuels Digest Magazine Stakeholder Representative, Sustainable Aviation Fuels Northwest Secretary (former), Governing Board, National Biodiesel Board Member, Northwest Energy Angels Member, Washington Clean Tech Alliance Section Member, American Bar Association, Environment, Energy and Resources Partner (206) direct (206) fax jgnoyes@stoel.com Education University of California, Davis, J.D., 1991 Staff editor, U.C. Davis Law Review Order of the Coif University of Virginia, B.A., 1987, with distinction Admissions Washington California District of Columbia U.S. District Court, Northern California U.S. Court of Appeals, District Columbia Circuit Graham s full bio profile is available at

24 S a r a E. B e r g a n Experience Sara Bergan is an associate in the firm's Energy Development and Environmental Law practice groups. She has particular experience working with clients in the renewable and low-carbon energy sectors, advising them on project development, project finance and related energy and environmental regulatory matters. Prior to her legal career, Sara was active in the energy policy arena in the Midwest. She served as the executive director of a non-profit organization that brokered consensus energy policy and project decisions among Midwest representatives of utility, government, regulatory, industry, agricultural and environmental interests. As part of her work at the Great Plains Institute, she also oversaw applied research related to advanced biofuels development. Representative Work Recent examples of her work include: Represented clients in various RFS2 compliance matters Helped prepare the private placement memorandum for an advanced biofuels company Part of a team advising multiple clients in complex tax equity and debt financings involving solar facilities in New Jersey, Massachusetts and New York Assisted client with the acquisition of a portfolio of solar energy projects in New York. Advised wind clients on the large energy facility permitting process in Minnesota. Prepared, filed and defended qualifying facility ( QF ) status for clients with the Federal Energy Regulatory Commission and assessed a variety of state PURPA laws for several clients with QFs Professional Activities Advisory Council Member, North Central Region Sun Grant Initiative Related Publications "Project Financing and Government Programs" Chapter, The Law of Biorefineries and Advanced Biofuels, Stoel Rives LLP, 2012 Edition Monitizing the Green in Green Power: Renewable Energy Certificates Chapter, Lex Helius: The Law of Solar Energy, Stoel Rives LLP, Third Edition Co-author, Densification: Associated Legal Challenges and Opportunities, Biomass Magazine, Nov Contributor, Stoel Rives Renewable Energy & Climate Policy Law Blog Associate (612) direct (612) fax sebergan@stoel.com Education University of Minnesota School of Law, J.D., 2010, magna cum laude Donald G. Marshall and Stone Scholarship Recipient Princeton University, M.P.P., 2006 Certificate in Science, Technology and Environmental Policy Gustavus Adolphus College, B.A., Environmental Studies, 1997, cum laude Admissions Minnesota Oregon Sara s full bio profile is available at

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