EPA Guidance on Potentially Illegal RIN Trading Practices
Posted by CITIZEN POWER ALLIANCE at 5:53 PMThe Environmental Protection Agency (EPA) recently publicized practices that it claims are illegal under its complex system for documenting compliance with the Renewable Fuel Standard. The system requires obligated parties to establish that they have purchased sufficient Renewable Identification Numbers (RINs), which are generated by the sale of renewable fuels such as biodiesel and ethanol. The EPA notice suggests that some RIN market participants' efforts to correct clerical errors in their RIN transactions may be creating additional civil exposure. Properly documenting RIN transactions has been a source of substantial concern to producers, marketers and purchasers of renewable fuels. The EPA's recent notice probably exacerbates those concerns for past transactions but does provide some useful guidance for future transactions.
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