PTQ Q4 2024 Issue

engineer who completes and submits an ‘engineering review’ report with supporting documents to the USEPA for acceptance. Although the on-site inspection can pro - ceed if the facility is not in production, the facility must be ‘substantially complete’. This means that construction is complete and all necessary equipment is installed. Before the registration information is submitted to the USEPA, the company must designate a Responsible Corporate Officer (RCO) who assumes full legal liability for all information provided to the USEPA on behalf of the company. The company is required to provide supporting evidence of the individual’s authority to accept this respon- sibility. Delays in project completion and attempts to assign a non-qualifying individual as an RCO are common causes of delays in the registration process. Many feedstocks, even those listed in existing, approved pathways, must meet multiple regulatory requirements to be considered as ‘qualifying’ feedstocks under the RFS. Virgin, crop-based oils that are sourced from crops grown in North America, such as soybean and canola oil, qualify under the RFS with minimal supporting information. However, crop oils sourced from outside North America will qualify only by providing extensive evidence of agricultural land use of all farmland since 2007, including supply-chain traceability and segregation, for which the USEPA requires Global Positioning System (GPS) coordinates. Though time-consuming, this information, in some cases, can be obtained from govern- ments and farmers who have tracked their lands for decades. Waste-based feedstocks such as biogenic waste fats, oil and greases (FOG), including used cooking oil and tallow, require supply-chain traceability to the point of origin (such as restaurant, food service, or food processor) and segre - gation guidelines. Distiller’s corn oil (DCO) and technical corn oil (TCO), meanwhile, require supply-chain traceabil - ity to the ethanol plant and potential farmland traceability. Blockchain providers are now supporting the industry to meet these criteria. If any element differs from the pathways listed in Table 1 to §80.1426, whether it is the feedstock, process technol - ogy used, or fuel type, the USEPA requires the submission of a pathway petition. Based on EcoEngineers’ experience, successful petitions require a thorough knowledge of and data on the feedstock, process, and product. Each invest - ment will have unique requirements; however, there are

Renewable fuels (D6) Corn ethanol - D6 Other grandfathered biofuels - D6

20% GHG reduction

Advanced biodiesel fuels (D4 & D5) Biodiesel - D4 Renewable diesel - D4 Non-cellulosic renewable CNG/LNG - D5 Sugarcane ethanol - D5

50% GHG reduction

Cellulosic fuels (D3 & D7) Cellulosic ethanol - D3 Renewable CNG/LNG - D3 Cellulosic diesel -D7

60% GHG reduction

Figure 1 GHG emissions by fuel type – RFS Courtesy: USEPA

reduce the quantity of fossil fuels used in the transportation and home heating oil markets. Obligated parties, like refin - ers and importers, achieve compliance by obtaining and retiring enough Renewable Identification Numbers (RINs) to meet their annual renewable volume obligation (RVO) for four different renewable fuel categories (D3, D4, D5, and D6) as shown in Figure 1 . Unlocking RIN values for biofuels like RD and SAF is straightforward as long as companies follow the ‘recipe’ of the USEPA‘s approved pathways by following its prescribed combinations of fuel type, feedstock, production process, and GHG reductions compared to baseline petroleum-derived fuels. These pathways are listed in Table 1 to §80.1426 under Subpart M of the RFS (see Figure 2 ). Note that Pathway H includes co-processing with petroleum (D5 RIN). If a producer’s fuel pathway already exists in Table 1 §80.1426, the next step is to complete the RFS registration process. This process includes a third-party engineering review of design documents, organisational structure, oper- ating and environmental permits, process flow diagrams, energy usage, and production inputs and outputs. An on-site inspection is performed by a licensed professional

Feedstock Applicable D codes for each fuel pathway for use in generating RINs o o Production process requirements

Fuel type h

D-Code

Fuel type

Biodiesel, renewable diesel,

Soybean oil; oil from annual cover crops; oil from algae grown photosynthetically;

One of the following: transesterification with or without esterification

jet fuel and heating oil Biodiesel, renewable diesel, jet fuel and heating oil

pretreatment, or hydrotreating; includes only processes that co-process renewable biomass

biogenic waste oils/fats/ greases; camelina sativa oil; distillers corn oil; sorghum oil; commingled distillers corn oil; and sorghum oil; canola/rapeseed oil

(advanced)

and petroleum

Figure 2 Excerpt of Table 1 to §80.1426: Applicable D codes for each fuel pathway for use in generating RINs Courtesy: USEPA

PTQ Q4 2024