The Biotechnology Industry Organization (BIO) today asked the Environmental Protection Agency (EPA) to consider changes to the proposed RFS Renewable Identification Number (RIN) Quality Assurance Program (QAP) proposal. The agency invited comments on its proposed voluntary quality assurance program, which was drafted to address recent instances of fraudulent RIN generation by three renewable fuel producers.
“The RFS is the single most important federal policy driving investment and commercialization of conventional and advanced biofuels. Investment spurred by the RFS has led to the development of commercial-scale advanced and cellulosic biofuel facilities that are currently in the process of starting up production of qualifying renewable fuel,” wrote Brent Erickson, executive vice president of BIO’s Industrial & Environmental Section in the comments. “Federal policies, including the proposed QAP, should clear a path for companies making investments, building new biorefineries and bringing innovative technologies to the marketplace.”
“The proposed QAP would place unnecessary and burdensome costs on biofuel producers—especially small producers recently achieving commercial status—which would not outweigh the potential benefits of the program on the RIN market. BIO recommends several changes to the proposed QAP to help ensure the RFS policy continues to encourage all biofuel producers to generate RINs,” Erickson continued.
BIO’s recommended changes would ensure the program is truly voluntary, that it does not enable potentially anti-competitive behavior, and that it does not impose costly, duplicative and unnecessary regulatory requirements on renewable producers in the early stages of commercial development. “Small producers, in particular, are being asked to incur costly and duplicative reviews of their facilities in exchange for verified status for RINs. There is no guarantee in the proposed QAP that verified RINs will provide a return on those costs. Yet, there is the potential that competitors can force these costs on small producers as a condition for RIN trading, thereby increasing costs to an intolerable level,” Erickson wrote.