Section 80.1164(a)(1)(ii) of the regulation states that the CPA conducting the attest engagement must obtain documentation of any volumes of renewable fuel used in gasoline during the reporting year; compute and report as a finding the volumes of renewable fuel represented in these documents. What does this mean?

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This provision is intended to require the CPA to include in his or her report any volume of renewable fuel actually used in gasoline produced at the refinery or imported by the importer, but is not intended to include renewable fuels added at a terminal downstream. The requirement is part of the attest engagement because renewable fuels are to be excluded from the volume of gasoline used to determine the refiner's or importer's RVO.

Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (pdf) (55 pp, 221 KB, EPA420-F-07-041a, August 2007)