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Will transmix processors be allowed to "stack" ethanol and exceed the maximum allowable oxygenate content without regard to VOC requirements?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Transmix processors who produce RFG are considered to be refiners and are required to meet all RFG standards and requirements that apply to refiners for the RFG produced, including the standards for oxygen and the renewable oxygenate. To…
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How will the volume of corn ethanol produced above the grandfathering threshold be treated?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . For grandfathered facilities, only the baseline volumes are exempt from the 20 percent GHG reduction requirement Thus, RINs may be generated for baseline volumes of fuel regardless of lifecycle greenhouse gas emissions performance. Volumes of fuel produced above…
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If blenders either opt not to trade or are not allowed to trade, who will be responsible for tracking these RINs through the system?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The blender must submit quarterly RIN transaction reports to EPA that will document all RIN transactions, including RIN purchases, RIN sales, and expired RINs. RINs that are reported purchased and thereafter are not sold will be identifiable through…
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Was Jatropha analyzed for this final rule and, if so, what D-code applies?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The GHG emissions performance of a Jatropha-based pathway was not analyzed for the final rule because sufficient information was not available. Since EPA has not yet assigned a D code for this pathway, a producer cannot generate RINs…
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Prior to the RFS rule, industry has used an equation for standardization of ethanol volumes that carries the correction factor out to 5 digits rather than 7 digits as in the formula given in the RFS rule at 80.1126(d)(7)(i). Will use of the equation curre
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Because the difference between the five-digit and seven-digit factors is extremely small, regulated parties may find that it makes no practical difference whether they use the shorter factor for batches of a certain size . If it makes…
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We are considering developing a PTD that lists ethanol and denaturant as separate items being transferred. RINs would be generated for the entire volume of denatured ethanol. If, for example, we transfer 950 gallons of ethanol and 50 gallons of denaturant
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The RINS should not be split between ethanol and denaturant. Section 80.1153(a) of the RFS rule refers to "the volume of renewable fuel that is being transferred" as necessary information for PTDs. Denatured ethanol is the "renewable fuel"…
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Do grandfathered facilities have an additional 6 months to submit their engineering reviews to EPA?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. In the preamble to the final RFS2 regulations at 75 Fed. Regs. 14709 (March 26, 2010), EPA stated that, in an effort to reduce demand on engineering resources in the interim between promulgation of the rule and…
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If a specific refinery is the producer of renewable diesel, I assume they need a facility ID number, but we can use the RINs for aggregate company compliance.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. The facility ID number is used to generate the RIN, but the RIN can be separated and used for compliance on a company-wide aggregate basis, subject to any applicable restrictions in the regulations such as regulation Sections…
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May records, regardless of whether they are paper or electronic, be stored off-site?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. Refiners, oxygenate blenders and importers must indicate where records will be kept on all facility registrations.(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…
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Will the Complex Model for NOx emissions take additive effects into account?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. However, the Complex Model can be augmented through the vehicle testing procedure outlined in the final rule to include the emission effects of an additive.(7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline…
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Will internal auditors be able to perform the attestation audits under the direct supervision of an independent CPA firm? Can the internal audit department meet the attestation requirement using CPAs rather than CIAs?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Section 80.125(c) provides that an independent CPA (or firm of CPAs) engaged by a refiner, importer or oxygenate blender may complete the attest engagement requirements with the assistance of internal auditors so long as such assistance is in…
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What is the definition of a responsible corporate officer (RCO) who is required to certify some of the submissions involved?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Under § 80.75(n), reports to EPA must be signed and certified as correct by the owner or a responsible corporate officer of the refiner, importer, or oxygenate blender. "Owner" means the person who is the principal owner of…
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What is meant by "grandfathered" fuel?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Under the RFS2 regulations, renewable fuel produced from facilities that commenced construction before December 19, 2007 and which completed construction within 36 months without an 18 month hiatus in construction and thereby exempt from the minimum 20% GHG…
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Can oxygen and benzene credits be transferred from the RFG area where they are created to another RFG area?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Benzene and renewable oxygenate credits may be transferred from the refiner or importer who creates the credits to any other refiner or importer who would use the credits. Oxygen credits may be transferred from the refiner, importer, or…
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Is the licensed professional engineer conducting the engineering review required to perform the site visit in person, or can they delegate the site visit to another person who maybe assisting them in the engineering review?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Pursuant to §80.1450(b)(2), all verifications must be performed by the licensed professional engineer conducting the engineering review. This requirement includes conducting the site visits. The licensed professional engineer conducting the engineering review must perform the site visits to…
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