If a facility is grandfathered, is it also exempt from the requirement that feedstocks must be renewable biomass?

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Even if a facility is exempt from the 20% GHG reduction requirement, in order to generate RINs, the facility is still required to use feedstocks that meet the definition of renewable biomass. The definition of renewable fuel in 80.1401 specifies that renewable fuel be made from renewable biomass, which is also defined in that section.