Weaver has been approved by the EPA as a QAP provider utilizing our RIN-tegrity® review program for U.S. producers/importers and foreign producers for the following pathways:

Weaver’s QAP Program:

EPA QAP Program: RIN-tegrity®

Corn Ethanol Biodiesel Renewable Diesel

SorghumEthanol

CNG/LNG RenewableNaphtha

Sugarcane Ethanol Cellulosic Fuels

Review purchase contracts, invoices and bills of lading, certificates of analysis and separated food waste plans.

Confirmation of the qualifying separation activities and their associated timing.

Site visit(s) by a professional engineer from Weaver or one of our strategic partners to facilitate production compliance.

Verification of activity reported to EPA vs. producer’s records, and creation of an accurate documentation history.

Review RIN generation calculations, fuel sales contracts, product designations, certificates of analysis and product transfer documents.

Verification of company, facility, fuel registrations and grandfathered status per EPA requirements.

Feedstock Production Process RIN Generation

RIN Separation Reporting & Record Keeping

Registration

Additional services required for foreign-sourced & crop-based feedstock

For Foreign Facilities/Imports: Steve Schwarzbach, CPA Partner Energy Compliance Services steve.schwarzbach@weaver.com 832.320.3420

Weaver’s QAP Benefits

Obligated parties that use Q-RINs for compliance obtain an affirmative defense against penalties if the RINs are later found to be invalid. The EPA also offers a limited exception for Q-RINs used for 2014, 2015 and 2016 compliance years equal to 2% of each RVO category. This protection means Q-RINs add value to the production facility, presenting new contract opportunities and enhanced marketability of the RINs.

Quarterly analysis by Weaver also offers insights into facility performance. The QAP review is consistent with an EPA audit, so that the producer is prepared if selected for a visit by the EPA.

Who We Help:

⊲ Renewable fuel producers, importers, blenders and marketers ⊲ Foreign renewable fuel producers ⊲ Biogas producers ⊲ Refiners and importers of gasoline, diesel and other refined products ⊲ Midstream transportation and storage companies ⊲ Trading companies

For more information contact: Wade Watson, CPA, CFE Partner-in-Charge Energy Compliance Services wade.watson@weaver.com 832.320.3262

For Domestic Facilities: David Bennett, CPA, CFE, CFF, CITP Partner Energy Compliance Services david.bennett@weaver.com 832.320.3285

Individual pathways covered under Weaver’s pathway-specific QAPs

Million RINs verified under Weaver’s QAPs

280 Weaver is 1 of only 5 companies approved by

the EPA to provide QAP verification services. 700+

© Copyright 2016, Weaver and Tidwell, L.L.P.

Weaver has offices in Austin, Conroe, Dallas, Fort Worth, Houston, Los Angeles, Midland, San Antonio and Stamford. For more information visit weaver.com.