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Fuels Registration, Reporting, and Compliance Help

How does a renewable fuel producer document that the MSW feedstock that they are using to produce cellulosic ethanol meets the definition of separated MSW as defined in Section 80.1426(f)(5)(i)(C )? How does the producer quantify the portion of the final

The renewable fuel producer using separated MSW feedstock to produce renewable fuels such as cellulosic ethanol, cellulosic diesel, cellulosic naphtha, etc. must document that their feedstock meets the definition of separated municipal solid waste (MSW), which is "material remaining after separation actions have been taken to remove recyclable paper, cardboard, plastics, rubber, textiles, metals, and glass from municipal solid waste, and which is composed of both cellulosic and non-cellulosic materials" pursuant to §80.1426(f)(5)(i)(C ). For such waste streams to qualify as separated MSW, it must be collected according to a plan submitted to and approved by U.S. EPA under the registration procedures specified in §80.1450(b)(1)(viii). This plan must have specific information, including the following:

  1. The location of the municipal waste facility from which the separated food and yard waste is collected.
  2. Extent and nature of recycling that occurred prior to receipt of the waste material by the renewable fuel producer;
  3. Identification of available recycling technology and practices that are appropriate for removing recycling materials from the waste stream by the fuel producer; and
  4. Identification of the technology or practices selected for implementation by the fuel producer including an explanation for such selection, and reasons why other technologies or practices were not.

EPA is in the process of developing additional guidance for the MSW Separation Plan.

In order to quantify the portion of the final renewable fuel volume that qualifies as cellulosic biofuel for purposes of generating RINs, the producer is required (pursuant to §80.1426(f)(5)(v)) to use the carbon-14 dating test method described in §80.1426(f)(9). The carbon-14 test method quantifies the fossil fuel portion of the final fuel and the remaining volume that is not the fossil fuel portion qualifies as cellulosic biofuel.