Learn the Issues
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What are the recordkeeping requirements for a renewable fuel producer that uses used cooking oils and fats as feedstocks for renewable fuel?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Renewable fuel producers using used cooking oils or animal wastes as feedstocks are required under 40 CFR 80.1454(d)(3) to obtain from their feedstock supplier, and maintain in their records, documents which certify that the feedstock meets the definition…
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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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Is the volume of renewable fuels a fixed number of gallons? How does this affect an obligated party's requirements?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The volume of renewable fuel used as the basis for calculating the percentage renewable fuel standards is fixed by CCA 211(o)(2)(B) for certain years (through 2012 for biomass-based diesel and 2022 for other renewable fuels), with volumes after…
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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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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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Does a renewable fuel producer have to report and maintain records on the feedstocks for every batch of renewable fuel they produce?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . All renewable fuel producers must report and maintain records concerning the type and amount of feedstocks used for each batch of renewable fuel produced (see 80.1451(b)(1)(ii)(K) and 80.1454(b)(3)(vi)). With regard to the renewable biomass recordkeeping and reporting requirements…
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What if pricing changes after the information has been reported to EMTS?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Parties will not be required to resubmit price information if it changes. The price information must be accurate rounded to the nearest cent (US Dollar) at the time the transactional information is sent to EMTS.
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Under "Business Activities" on the Company Details CDX web page, what does "Small Blender" mean?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The small blender business activity is in relation to §80.1440: "What are the provisions for blenders who handle and blend less than 125,000 gallons of renewable fuel per year?" The small blender business activity entry is for those…
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How will engineering reports be treated in terms of public access and CBI? Will there be web access for submitted reports?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA will process any public requests for engineering reports on a case-by-case basis and there will be no general web access to the engineering reports. Engineering reports, or portions thereof, for which the submitter asserts a confidential business…
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Which fuels are exempt?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Exempt are fuels or fuel additives marketed solely for use off-road, such as non-road diesel or fuel additives solely for use in marine engines, and on-road fuels that are not gasoline or diesel, such as E85 or compressed…
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Under what conditions might a renewable fuel produced under an approved pathway in the RFS regulations qualify for use in Navy applications?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Background: The U.S. Navy is seeking to blend biofuels with fossil-based fuels, such as F-76 fuel, which are often used in Navy marine vessels. The Navy asked EPA for guidance on whether such biofuels would be treated as…
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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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A refiner produces a batch of gasoline at its refinery. It collects a sample of the gasoline and conducts certification testing. The sulfur content test result is less than the 80 ppm refinery level standard. The gasoline is then moved to another tank wit
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The downstream standard applies to samples of gasoline subsequent to movement of the gasoline from the tank in which certification sampling is conducted, even when these subsequent samples are collected within the refinery or import facility where the…
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Is the Renewable Fuels Mandate in ethanol equivalent gallons?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The percentage standards applicable under RFS are intended to be met with ethanol-equivalent volumes of renewable fuel. As a result, a gallon of ethanol counts as one gallon of renewable fuel for purposes of compliance with the four…
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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…
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For a transfer in ownership of a volume of renewable fuel, may a party include the applicable product transfer document (PTD) language required at §80.1453(a)(12) on an accompanying PTD for RINs assigned to that renewable fuel as described in §80.1453(a
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. Under §80.1453(a), PTDs must identify a transfer of ownership of a volume of neat and/or blended renewable fuel or separated RINs. In general practice, this would mean invoices or bills of lading. However, in the case where…
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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…
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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.
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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%…
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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…