How can a marketer transfer RINs with a K code of 1 and fulfill the requirement that "No person may transfer a RIN that has a K code of 1 without transferring an appropriate volume of renewable fuel to the same person on the same day" ?
A party may transfer any volume of renewable fuel to any other party without simultaneously transferring any assigned RINs to that same party.
However, assigned RINs can only be transferred to another party in association with the transfer of a volume of renewable fuel. Under regulation Section 80.1128(a)(4), the ratio of assigned RINs transferred to gallons transferred can be anywhere between zero and 2.5.
Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (PDF) (55 pp, 221 K, EPA420-F-07-041a, August 2007, About PDF)