Free, downloadable white paper on Renewable Fuel Standard navigates the complexities
In Texas, RINStar and Stoel Rives released a free, downloadable, white paper on the new Renewable Fuel Standard (RFS2), in “America Advances to Performance-Based Biofuels”.
The three defining characteristics of RFS2, according to the authors, are its massive scale, complexity and demanding requirements. Market participants will still be required to utilize Renewable Identification Numbers (“RINs”) to track transactions and demonstrate compliance. What has changed is that there are now multiple types of RINs to correspond to new types of fuel.
In addition, new GHG-driven EPA rules mandate a well-to-wheels lifecycle analysis (“LCA”) that examines all factors impacting GHG performance for a particular fuel.
Within this changing landscape, the white paper attempts to describe the legal and practical context for a variety of industry participants. Since this audience is diverse and ranges from renewable fuel producers, importers and product traders to independent petroleum marketers, fuel cooperatives and petroleum refiners, multiple RFS2 topics are discussed in some detail.
First, the legal background for the RFS2 is discussed along with the new legal requirements imposed by the legislation. Second, the key compliance system of RINs is reviewed with attention to practical changes to the prior system and compliance obligations. Third, a series of issues important to particular market participants is discussed in more detail. These topics include producer obligations, new fuel pathways, importer issues and RIN trading economics. Finally, a series of recommendations for upgrading to RFS2 is provided for market participants.
The white paper is downloadable here.
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Category: Policy
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