Ginger –You are correct that small importers are exempt from the recordkeeping and reporting requirements, but the annual threshold to qualify under that definition is 250,000 gallons and only 12 out of 64 registered companies qualified for this. The recordkeeping for everybody else included:
· Volume of fuel;
· Names of the transferor and recipient;
· Whether the compliance obligation was transferred from the transferor to the recipient or retained;
· Carbon intensity of the fuel;
· Producer of the fuel;
· Invoice date;
· Unique transaction identification such as a bill of lading number;
· Product transfer documents;
· Exempt status documentation under OAR 340-253-0250, if fuel is excluded from surplus and shortfall calculations under OAR 340-253-1010; and
· For fuel that is exported outside Oregon, where the party is the exporter of record.
The proposed change is for all importers to keep records of things they should already be doing as a typical business practice:
· Transaction date, unique transaction identification number;
· Transaction type;
· Volume of fuel;
· Name and FEIN of the transferor and recipient;
· Product transfer documents;
· Exempt status documentation under OAR 340-253-0250, if fuel is excluded from surplus and shortfall calculations under OAR 340-253-1010; and
· For fuel that is exported outside Oregon, where the party is the exporter of record.
and additional recordkeeping for importers of blendstocks including:
· Fuel pathway code and approved carbon intensity of the fuel;
· Name of the biofuel producer and its physical location, EPA company ID and facility ID number; and
· Physical pathway code.
The registration tool was developed to help companies keep records if they did not have a system of their own, but it is not required.
Currently, quarterly and annual reports are required. The California reporting tool is being converted for use in Oregon to facilitate these requirements.
There is no plan for a carbon cap and trade in Oregon at this time.
In phase 1 of the program, shortfalls and surpluses are compared to a baseline carbon intensity value to determine a net balance.
The current program does not allow for non-importers to participate…I anticipate having a discussion about allowing out-of-state producers and marketers to participate in the future if the program continues. That said, our advisory committee felt strongly that non-regulated third parties should not be permitted to purchase or own credits in the clean fuels program.
Let me know if you have additional questions.
Cory-Ann Wind
Air Quality Planner
wind.cory@deq.state.or.us
503-229-5388
From: Ginger Laidlaw [mailto:Ginger@RINAlliance.com]
Sent: Tuesday, October 15, 2013 11:08 AM
To: WIND Cory Ann
Subject: RE: Oregon Clean Fuels Program
Hi Cory – I’ve just taken a look at the proposed changes to the OR Clean Fuels Program as we try to stay in the know for our clients who may be importing blendstocks and finished fuels. Right now, it is my understanding that what is currently required of regulated parties is to make sure that they are registered, and now they need to be retaining records via the recordkeeping template. Are quarterly reports being required currently? Eventually, the plan is to have a carbon cap and trade once the shortfalls and surpluses are calculated, correct? Is there currently any option for third-party consulting/broker to register or participate in this program – do you anticipate this in the future?
I appreciate your help!
Thank you,
Ginger Laidlaw
Project Manager
RINAlliance
866-433-7467
From: WIND Cory Ann [mailto:WIND.Cory@deq.state.or.us]
Sent: Tuesday, June 11, 2013 4:16 PM
To: Ginger Laidlaw
Cc: WIND Cory Ann
Subject: RE: Oregon Clean Fuels Program
Hi Ginger,
Here is a link to our website: http://www.deq.state.or.us/aq/cleanFuel/index.htm. At the top left, there is a little green envelope – click it to enter your e-mail address to receive program updates. You’ll also see hyperlinks to the actual rules and if you click on The Regulations, it will take you to the parts of the program we are currently implementing. As a general note, Oregon is working with California to adopt their reporting tool for use in Oregon, so although we may have specific rules right now, that will probably change to be consistent with the tool (rather than vice versa). Our goal is to harmonize the information as much as possible. Access to the Excel spreadsheet template used for recordkeeping and the reporting tool will be available there when they are ready.
Please feel free to contact me if you have any additional questions.
Cory-Ann Wind
Air Quality Planner
503-229-5388
From: Ginger Laidlaw [mailto:Ginger@RINAlliance.com]
Sent: Tuesday, June 11, 2013 2:05 PM
To: WIND Cory Ann
Subject: Oregon Clean Fuels Program
Hi Cory-Ann! RINAlliance developed a RIN management and marketing system for the Renewable Fuel Standard for blenders registered with the EPA. We have some clients on the West Coast, so we have been monitoring the CA LCFS, and have started to review the OR Clean Fuels Program. As part of our system, we assist our clients generate product transfer documents and I have been trying to research what potentially needs to be included on PTDs to fulfill the requirements of the Clean Fuels Program. Any help would be appreciated. Also, is there an email distribution list I could register for updates to the program?
Thank you,
Ginger Laidlaw
Project Manager
10430 New York Avenue, Suite F | Urbandale, IA 50322 | 866-433-RINS (7467) office | 515.224.0502 fax | Ginger@RINAlliance.com | www.RINAlliance.com
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