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If I have a renewable fuel that was assigned a specific Equivalence Value in regulation Section 80.1115, but I don't think that Equivalence Value is right for my product, what options do I have?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Producers or importers of renewable fuel may submit a petition to the EPA requesting a different Equivalence Value from that assigned in the regulations. However, the petition must use the calculation methodology described in regulation Section 80.1115(d). In…
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What are the RFS2 requirements for renewable fuel producers to track soy feedstocks?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Since soy is considered a planted crop for purposes of RFS2, producers of renewable fuel made from soy grown on U.S. agricultural lands are covered by the aggregate compliance approach in §80.1454(g). Those producers using domestic soy need…
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I understand under CAA Section 211(o), compliance can be deferred for a year as long as the obligated party complies the next year. How does one petition for a one-year deferral? What criteria are considered?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . According to §80.1427(b), an obligated party may carry a deficit from one compliance year to the next under certain conditions. No petition for a deficit carryover is required. An obligated party will be presumed to be carrying over…
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Will carbon monoxide non-attainment areas have to market 2.0% oxygen during one season and 2.7% oxygen during another season?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . If an RFG area is also an oxygenated fuels program control area, then the RFG distributed to that area during the designated carbon monoxide control season will, pursuant to section 211(m) of the Act, require an average of…
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To whom does the 20% limit on previous year RINs apply?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . This limit applies only to obligated parties. Under regulation Section 80.1127(a)(2), no more than 20% of the gallon-RINs used by an obligated party to meet its RVO can be previous-year RINs (having a YYYY code that is one…
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The batch report requires reporting the volume percent for six oxygenates -methanol, MTBE, ethanol, ETBE, TAME and t-butanol. If a refiner or oxygenate blender uses MTBE or ethanol as an oxygenate, and does not include in its calculation of oxygen weight
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Trace amounts of oxygenates that may be present in MTBE or ethanol do not have to be reported. However, where a refiner reports total oxygen weight percent that includes MTBE or ethanol plus other oxygenates in larger than…
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The final rule on page 23909 (Federal Register, volume 72) states that any non-obligated party that takes ownership of the renewable fuel with RINs will be required to transfer those RINs with a volume of renewable fuel. Does this refer to oxygenate blend
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No, as long as the blender actually blends the renewable fuel into gasoline or diesel. In that case, the blender would be required to separate the assigned RINs from the blended renewable fuel, and could then transfer the…
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Will non-obligated parties in possession of RINs create a RIN shortage?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The in-use production volumes of renewable fuel are expected to exceed the requirements of the RFS program by a substantial margin. As a result, we expect there to be a surplus of RINs for at least the first…
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Will non-obligated parties that can hold title to RINs be required to balance them each quarter?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Every party that owns assigned RINs must comply with the end-of-quarter check described in regulation Section 80.1128(b)(5). This provision ensures that RINs must be transferred with renewable fuel as renewable fuel moves through the distribution system. However, this…
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Are engineering drawings and process and instrumentation diagrams (P&IDs) required to be submitted as part of the engineering report?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Engineering drawings or P&IDs are not required to be submitted in the engineering report, but EPA suggests the third party engineer provide a simple diagram to help supplement the description of the process train for each renewable fuel…
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What is the final form of the batch identification number?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . A batch ID is made up of the 4 digit company ID, 5 digit facility ID, 2 digit reporting year, and the 6 digit batch number (e.g., CCCC-FFFFF-YY-BBBBBB).(7/1/94) This question and answer was posted at Consolidated List of…
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Where should registrations and reports be sent?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . U.S. Environmental Protection Agency Attn: REFGAS (6406J) 1200 Pennsylvania Ave., NW Washington, DC 20460 (7/1/94) This question and answer was originally posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November…
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Does regulation Section 80.1128(a)(4) allow a marketer to change the K code from 1 to 2 and then not transfer the RIN with the renewable fuel as long as he sells the RINs to anyone by the end of the quarter?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Marketers who buy and sell renewable fuel without blending it into gasoline or diesel cannot separate RINs from volumes, and thus cannot change the K code from 1 to 2. All conditions under which a party can separate…
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It appears we are creating an automatic non-compliance period for September, 2007. If I own ethanol on September 1, 2007, it will not have assigned RINs. As an obligated party, I will be blending this ethanol into gasoline at my terminal, but I won't be g
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . It may be the case that some ethanol blended into gasoline at the beginning of the program will not have assigned RINs. However, the RVO is determined annually, not quarterly or monthly, and in general ethanol purchased after…
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A refinery can produce non-ester renewable diesel by processing renewable feedstock through a distillate hydrotreater. In this situation, the refinery must assign RINs based on the feed volume. I assume the refinery can follow the rules for defining a bat
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. However, it is the total number of gallon-RINs, not the total volume, that must be less than 100 million. See regulation Section 80.1126(c). Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel…
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