Obligated parties submit RIN reports

By Susanne Retka Schill | July 08, 2008
The U.S. EPA is reviewing the first round of annual reports summarizing recorded renewable identification numbers (RINs) under the renewable fuels standard of the Energy Independence & Security Act of 2007. An estimated 1,000 companies filed their first yearly summaries, called attest engagements, by the May 31 deadline.

Not all companies filed, however. EPA spokeswoman Roxanne Smith explained that the regulations contain a provision that allows certain parties to file their 2007 attest reports along with their 2008 reports due May 31, 2009.

The EPA has yet to review the attest engagement reports, she told EPM at press time. "We heard from a number of [certified public accountants] that the attest engagements identified and helped correct problems with tracking and reporting RINs for many companies," she said. David Bennett, certified public accountant for RIN Attest and Advisory Services in Connecticut, has conducted approximately 30 attestations for various RIN-holding companies in the United States since March. He told EPM that there were quite a few companies that experienced problems when compiling data for filing. He said the main problem was that not all companies have efficient ways of tracking their data. "For a lot of small companies that don't have sophisticated, dedicated software they're using [Microsoft] Excel [to track RIN movement]," he said. "For companies that have the resources and abilities, they can build and buy a system that has those templates built into it so that hopefully at the end of the quarter all they have to do is push a button, and all the data is compiled and the appropriate reports are output."

Bennett said companies that don't use specific software have to rely on the manual input of numbers, resulting in a large margin for human error. The EPA is aware of this problem and, as a result, mandates an annual certified public accountant audit to rectify any errors that may have occurred throughout the company's yearly record-keeping.

Lack of knowledge on how to properly keep track of RINs has been another problem for companies, according to Bennett. "The EPA tells what to do, not how to do it," he said, adding the agency is aware of the problem. In an attempt to better inform companies that deal with RINs, the EPA has begun issuing question-and-answer documents on its Web site every few months.

Bennett suggests that obligated ethanol companies appoint a person to become familiar with RIN regulations and how they apply to the company. This should be the person's sole focus, he suggested, as it is intensive work.

More information on the requirements can be found at www.epa.gov/otaq/regs/fuels/attestengage.htm.