Learn the Issues
-
Would a refinery that receives RBOB from another refinery and blends oxygenate(s) with that RBOB to make RFG also have to register as an oxygenate blender?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. Under § 80.2(mm), an oxygenate blender means "any person who owns, leases, operates, controls, or supervises an oxygenate blending facility, or who owns or controls the blendstock or gasoline used or the gasoline produced at an oxygenate…
-
Who is the transferee in a custody transfer where the owner of the receiving tank/truck/barge is different than the operator (scheduler) of the tank/truck/barge, who may also be different from the company that provides the employees of the site? Can a com
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Regarding transfers of custody, PTDs are intended to be given to the person physically taking custody of the product. Where multiple parties are involved in a physical transfer of the product, and the transferor does not know the…
-
How long will the grandfathering provision be effective? Once a grandfathered producer registers and completes their engineering review, will their baseline volume ever need to meet the 20% GHG reduction requirement?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . If a facility meets the requirements for exemption from the 20% GHG reduction requirement pursuant to 40 CFR 80.1403(c ) or (d), then the baseline volume of renewable fuel produced by that facility is exempt from the 20%…
-
Will current canola based biodiesel production fall under the grandfathering provisions of the RFS2 regulations?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Biodiesel facilities may qualify for the exemption under 80.1403(c) from the requirement that renewable fuels achieve a minimum 20% GHG reduction as compared to baseline fuels if they "commenced construction" prior to the date of enactment of EISA…
-
We are a wholesaler of E100 and B100. We do not do any blending. We purchase and sell E100 and B100 and sell it to anyone who needs it. What in the RIN code must be changed to document the change of ownership?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Nothing changes in the RIN code to document a change of ownership. 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…
-
I will be making ethanol from both cellulosic feedstocks and corn in my plant. How do I know what Equivalence Value to use, and how do I assign RINs to batches?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . There are two possible ways to address this situation. If the volume of each type of ethanol can be measured independently and precisely (for example, in a facility where the conversion of cellulosic feedstocks to ethanol occurs through…
-
Would it be acceptable to provide all required product transfer document information on the bill-of-lading, including the transferee's name, except for the transferee's address, provided that the address is included on a follow-up invoice?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . As long as all product transfer documentation information is provided to the transferee, either prior to, during or immediately following the transfer of title or custody of the gasoline, the PTD requirements are met. As a result, it…
-
Will a foreign refiner or blender, or an importer of RFG produced overseas, be given some kind of credit for plant emissions outside the United States?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No. The RFG regulations do not extend to foreign refineries.(8/29/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF) (333 pp, 18.17…
-
If a producer is able to change its D code, can it make retroactive changes in the D code of the RINs it has issued previously during the year or earlier if the production during the previous period would meet the newly classified D code criteria?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Once a RIN is generated and transferred to another party, it cannot be changed. Thus, retroactive changes to D codes in RINs are not allowed.
-
We would describe ourselves as an ethanol marketer, but we import gasoline into one of the 48 contiguous United States. Does this make us an obligated party and, as an obligated party, are we able to separate RINs?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . If a party is an importer of gasoline into the 48 contiguous United States, then that party is an obligated party. Section 80.1129(b)(6) allows an obligated party to separate RINs they generated from volumes of renewable fuel, if…
-
If a plant establishes RINs at the beginning of the month and defines it as one month's production estimate (e.g. 8 million gallons), what happens if the plant produces more than 8 million gallons by the end of the month? Does the plant then start issuing
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . RINs are not generated at the beginning of a month. Rather, gallon-RINs must have been generated by the time a volume of renewable fuel is transferred from the producer or importer to another party (at which point the…
-
If an importer is unsure of what terminals might be involved in importing gasoline (RFG or conventional), may importers register more terminals than might be used?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. However, an importer does not need to register each import facility it uses (see previous question).(7/1/94) This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through…
-
Will EPA consider widening the limits on distillation?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The range of data on which the Complex Model was based limits the range within which the model will exhibit appropriate accuracy. The E200 range in the database was 33 to 66 vol%; extrapolation widened this range to…
-
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…
-
While there is no renewable fuel obligation under the RFS2 program for the production or importation of conventional jet fuel, RINs can be generated for renewable jet fuel. Is that right?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . As described in 80.1407, only gasoline and diesel fuels produced or imported into the U.S. are subject to the renewable fuel standards. Thus, only gasoline and diesel fuel volumes produced or imported by an obligated party factor into…
-
Refiners and oxygenate blenders who produce averaged reformulated gasoline must report which covered areas products have been distributed to by each facility. How are these areas to be determined?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Unless a refiner or oxygenate blender has specific and detailed information indicating otherwise, it must be assumed that products have been delivered to all covered areas serviced by the distribution system(s) used. A list of covered areas as…
-
What metering system does the plant use to measure gallons? Is it a production meter, a load-out meter, etc.?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA regulations provide flexibility in terms of the specific mechanisms through which producers and importers measure volumes for purposes of generating RINs. However, the approach should ensure that gallons are neither systematically ignored nor systematically double-counted. Also, approaches…
-
If you have a spill, does the K code change to 2 for the spilled volume?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No, the K code is not changed as the result of a spill. (Refer to section 80.1132 of the regulation regarding retirement of RINs due to a spill.) Question and Answer was originally posted at: Questions and Answers…
-
Once I register my fuel for the RFS2 program under §80.1450, do I still need to register my fuel under 40 CFR Part 79?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. Renewable fuels intended for use or used in motor vehicles are required to be registered under 40 CFR part 79 prior to any introduction into commerce. Manufacturers of renewable fuels and fuel additives not registered under part…
-
Will oversight programs and paper trail need to extend to conventional gasoline in order to comply with anti-dumping?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The requirements of the anti-dumping program apply only to refiners and importers. As a result, there are no downstream standards or requirements for conventional gasoline, other than those related to the prohibitions against using conventional gasoline in RFG…