Necessary Amendments to the Proposed Renewable Fuel Standard (RFS) Program Standards for 2023-2025  
  
On behalf of this document’s signatories, the following is requested:   
  
PRIMARILY that no rule shall be created that infringes on a compliant seller's ability to efficiently market their material to the buyer of their choice. 
  
A compliant seller shall be defined as a seller of used cooking oil who is in possession of AND efficiently able to transfer collection records pertaining to said material to a relevant QAP. 
A compliant seller’s ability to market their material can be damaged by regulations that: 
 
* Reduces seller’s access to, or flexibility within, markets to quickly and efficiently sell to buyers of their choice. 
* Creates an inelastic supply chain highly susceptible to backup, overflow, and market bid/ask illiquidity. 

It is the sentiment of the signatories that the currently proposed RFS 2023-2025 has the potential to result in these undesired outcomes. 
 
In response to, and in support of EPA’s desired intent, we propose the following changes. 
 
1. Require QAP on all UCO to maintain a level compliance landscape 

a. Participation in the 3rd party feedstock traceability program should be mandatory, not optional, for all UCO gallons receiving EPA support regardless of whether a standard or QAP RIN is ultimately produced. This would apply to both internally collected UCO gallons (integrated collector/producer) and volumes purchased from 3rd parties.  
b. Additionally, all aggregators and traders should be subjected to equal oversight, regardless of affiliation with a vertically integrated fuel producer. 

2. Allow both buyers and sellers to appoint their own QAP provider  
a. Mandate that all EPA approved QAP providers cooperate on behalf of their clients. Allow a seller QAP to allocate managed volumes to multiple buyers simultaneously.  
b. The EPA's proposal to give biofuel producers the OPTION of keeping all records in-house or using a 3rd party QAP creates an unlevel playing field with respect to oversight and compliance cost. 
c. All fuel producers, collectors, and traders should encounter the same degree of friction with respect to regulation. 
  
3. The EPA should maintain or contract out maintenance of a unified records archive  
a. The EPA must maintain a database to receive records submitted from all authorized 3rd party QAP auditors. Building and maintaining such a system with modern technology is feasible and enables multiple QAP providers to exist without giving up the ability to look for record duplication and re-use.  

4. The UCO recordkeeping and transmission format should be standardized 
a. Transmission format should be consistent, regardless of QAP provider chosen by a fuel producer, trader, or other participant. This enables both buyers and sellers with good recordkeeping to easily move between counterparties without sacrificing compliance, while maintaining and perhaps even improving, a competitive marketplace.  
b. To reduce the occurrence of theft and fraud, and to enable effective retrospective analysis, we recommend the following data points be required for UCO collections:   
* Collection company name    
* VIN # of collection vehicle    
* Unique employee ID of driver   
* Source name (I.e. Restaurant Name)    
* Source address    
* Service date & time    
* Total gallons    
* Estimated yield 
* Yield may be a location specific or companywide value. 
 
 
We sincerely thank you for your consideration. We look forward to a future in which feedstock is easily traceable, fraud is minimized, and independent operators—from mom-and-pops to national players—can compete in a vibrant marketplace.