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Renewable Fuel Standard Alternative Recordkeeping Options

September 05, 2014
Author: LeAndra Spicer

To meet the qualifications set forth by the Renewable Fuel Standards, renewable fuel producers must maintain adequate records related to both their feedstock and the land on which it originated. Recognizing the difficulty of this task, legislation provides an alternative. In lieu of retaining documentation on each load of biomass received at a facility, producers have the option to report using an alternative biomass tracking system.

Under the alternative system, a renewable fuel producer can “have an independent third party conduct a comprehensive program of annual compliance surveys or participate in the funding of an organization which arranged to have an independent third party conduct a comprehensive program of annual compliance surveys.”[1] An independent surveyor cannot be employed by a renewable fuels facility and must remain free from any obligation to or interest in a producer.[2]

The alternative approach requires producers to submit an annual compliance survey plan to the Environmental Protection Agency (EPA)--which the Agency must then approve--in the calendar year prior to the survey being conducted.  Independent surveyors must conduct on-site surveys representative of feedstock suppliers and renewable fuel producers. The surveys must also be designed to achieve the same level of quality assurance as traditional record-keeping requirements.

The independent surveyor is responsible for obtaining product transfer documents and other records associated with the feedstock in order to confirm who the renewable fuels producer’s feedstock suppliers are and whether feedstocks meet the EPA definition of renewable biomass. In order to make this possible, the producer is responsible for ensuring its suppliers cooperate with the surveyor.

Mitigating recordkeeping errors through internal supplier audits is not a viable option for a fragmented wood supply chain. Although planted trees and tree residue that comes off plantation land is part of a well-defined system of corporate ownership, slash and pre-commercial thinnings from non-plantation land will be sourced from a patchwork of private owners. Renewable fuel producers will more than likely not have contact with these private owners; rather, this source of supply will come to them through wood dealers. Including language within biomass supply agreements that requires suppliers to provide documentation that confirms the renewable status of delivered biomass is one option to overcome this challenge.

An advantage afforded by the alternative recordkeeping system is that it spreads the responsibility for maintaining documentation across the biomass supply chain and eases the burden of documentation on the producer. A downfall is that supplier shortcomings may be passed along to the producer. If a surveyor determines a supplier made errors in identifying the biomass it provided to a facility as renewable, then by extension those errors also belong to the producer. It will be up to the facility to decide if the advantages of the alternative recordkeeping system outweigh the challenges.

[1] US Environmental Protection Agency. 40 CFR Part 80. Regulation of Fuels and Fuel Additives: Changes to Renewable Fuel Standard Program; Final Rule. March 26, 2010.

[2] US Government Printing Office. Electronic Code of Federal Regulations: Compliance Surveys. §80.68 (c) (13) (i).

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