EPA approves “Koole-Neste Pathway” for D4 RIN production from SAF

In Washington, Koole Tankstorage Botlek B.V. (Koole) and Neste Oyj (Neste) asked the Envrionmental Protection Agency to approve a pathway for the generation of biomass-based diesel (D-code 4) renewable identification numbers (RINs) for renewable jet fuel and renewable diesel bottoms produced from renewable diesel through a fractionation process, where the renewable diesel was originally produced at the Neste Porvoo renewable fuel production facility by hydrotreating biogenic waste fats, oils and greases (“biogenic waste FOGs”) feedstock (the “Neste Porvoo Pathway”). Neste generates D-code 4 RINs, through existing pathways in Table 1 to 40 CFR 80.1426, for renewable diesel produced at their hydrotreating facility in Porvoo, Finland. Koole proposes to purchase renewable diesel produced through the Neste Porvoo Pathway with RINs attached, retire the attached RINs, fractionate the renewable diesel at the Koole facility in Rotterdam, Netherlands, and generate new D-code 4 RINs for the resulting renewable jet fuel and renewable diesel bottoms (the “Koole Rotterdam Fractionation Process”). The EPA calls the entire set of steps from the biogenic waste FOG feedstock to the renewable jet fuel and diesel bottoms the “Koole-Neste Pathway.”

Based on the EPA’s assessment, renewable jet fuel and renewable diesel bottoms produced through the Koole-Neste Pathway qualify under the Clean Air Act (CAA) for D-code 4 RINs, assuming the fuel meets the other definitional and RIN generation criteria for renewable fuel specified in the CAA and its implementing regulations.

EPA approved a similar pathway for Texmark Chemicals, Inc. and Neste in September 2019 (the “Texmark-Neste Pathway”). The primary difference between the Koole-Neste Pathway and the
Texmark-Neste Pathway is that Koole is a foreign producer and Texmark is located in Texas. Thus, additional conditions are specified in the attached determination to ensure the Clean Air Act and regulatory requirements are satisfied for imported renewable fuels.