Buried in the middle of the RFS 2 regulations published in February by the EPA are the new requirements for producer program registration. The rules as posted are only the proposed modification to 40 CFR 80, pending publication of the final regulations in the Federal Register, a legal requirement for final adoption.
If you are not already aware, even if your facility was registered under the first version of RFS, it must re-register prior to July 1, 2010 to participate under the auspices of the new program.
The new producer registration requirements are detailed in a densely packed section of the 120 page document.
Occupying roughly four (4) pages, the requirements include a description of the type of fuels produced at the facility (or possibly produced with little modification to the production process), Â feedstock used in the production process, the co-products produced with each fuel type, Â and the submission by a state licensed, third party, chemical engineer the results of a careful review of your facility process and capacity expectation.
These requirements come at a time when producers are particularly sensitive to issues surrounding cash flow and operating costs, and expenses like a third-party engineering review may seem ill-timed.
RFS 2 participation is important to us here at Promethean. It is a personal initiative for me and I am focused on preparing us to meet the July start date.
There still exists a subset of mysteries whose answers are yet to be revealed by the EPA regarding what the EPA will specifically require as an ultimate demonstration of conformance.
I hope clarity is imminent.
Make it a better place,