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January 13, 2017

Third Party Auditor May Lose Ability to Verify RINs

Kathleen M Roberts

On January 4, 2017, EPA issued a notice of intent to revoke Genscape’s ability to verify Renewable Identification Numbers (RIN) as a third party auditor under the Renewable Fuel Standard (RFS) Quality Assurance Program (QAP).  According to the notice, Genscape failed to meet all elements of its Quality Assurance Plan and verified approximately 68 million fraudulently-generated RINs.  To replace invalid RINs, Genscape is required to retire RINs within 60 days.  Obligated parties, however, do not have to replace invalid RINs to meet their compliance obligations if they assert and meet the requirements of an affirmative defense pursuant to 40 C.F.R. § 80.1473.  Genscape has 60 days to submit comments on the notice, which EPA will consider when taking final action on the proposed revocation. Unless EPA issues a final action to revoke its registration, Genscape may continue to function as a QAP provider.