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Fuels Registration, Reporting, and Compliance Help

Updated Engineering Reviews for Renewable Fuel and Foreign Ethanol Producers

This page will assist renewable fuel and foreign ethanol producers in completing their updated engineering review (ER) obligations under EPA’s Renewable Fuel Standard (RFS). This covers both updated 3-year ERs and updated ERs related to facility changes.

General Instructions

  • Producers should use this page in conjunction with the regulations, not in lieu of reading the regulations.
  • For a full description of the updated 3-year engineering review (ER) report requirements, see: 
  • For a full description of the updated ER report requirements related to facility changes, see:
    • Title 40 CFR Part 80.1450(d)(1)
  • Updated ER reports may no longer be submitted by mail and MUST be submitted electronically. See the last row in the step-by-step instructions table for more details.
  • Starting on April 1, 2018, updated ER reports must be submitted in OTAQREG using the ER webform by the third-party independent professional engineer (PE). The PE must be registered in CDX and associated with the company in OTAQREG to complete and submit the ER webform. Please refer to the webpage on user associations for instructions.
  • All producers of renewable fuel and foreign ethanol producers are required to submit an independent third-party ER report at registration and an updated ER report by January 31 of every third calendar year thereafter. For example, a renewable fuel facility initially registered in 2010 is required to submit a 3-year update by January 31 of 2013, 2016, 2019, and so on. To help provide clarity, the EPA has compiled a list of registered renewable fuel and foreign ethanol production facilities and a schedule for when updated 3-year ER reports are due.
  • If a renewable fuel or foreign ethanol producer submits an updated ER report with a VRIN analysis to EPA for a facility in the calendar year preceding the scheduled updated 3-year ER report due date, EPA will accept a letter documenting that submission on the next January 31 due date in place of the updated 3-year ER report.  

Step-by-step Instructions

  Steps for completing the three year engineering review update Additional Information
1 The renewable fuel or foreign ethanol producer must assemble all materials required under §80.1450(b)(1).
2 The renewable fuel or foreign ethanol producer must obtain an engineering review conducted by an independent third-party professional engineer per §80.1450(b)(2). The professional engineer must verify and explain how the accuracy of all materials assembled by the producer per §80.1450(b)(1) was evaluated.

Read the following guidance on items the engineer must verify:

3 The professional engineer must include a detailed review of the renewable fuel or foreign ethanol producer’s VRIN calculations per §80.1450(b)(3)(iii).

The VRIN calculation review is not required for foreign renewable fuel producers that do not generate RINs.

Read the following guidance on VRIN calculations:

4

If any registration information has become outdated, the renewable fuel or foreign ethanol producer must generate a Company Request (CR) for a Company Update in CDX OTAQREG.

If the Responsible Corporate Officer (RCO) has e-signature capabilities, he/she should e-sign the Company Update CR to complete this step in the process,

If the RCO does NOT have e-signature capabilities, print and mail the signed Company Update CR pages to:

If all registration information remains current, the renewable fuel or ethanol producer should not generate a CR in CDX OTAQREG.

For more information about Company Update CRs, read Section 7 "Update a Company" in this document:

For more information on RCO e-signatures, see:

5

The professional engineer should then submit the engineering review (ER) report via one of the following methods:

  • If the independent third-party professional engineer (PE) is associated with the renewable fuel or foreign ethanol producer in CDX OTAQREG with the “Independent Third Party Engineer” role, the PE should electronically submit the ER report and materials required under §80.1450(b)(1) to EPA. If associated, the PE has two options for electronic submission: 
    • Upload the ER report and materials required under §80.1450(b)(1) in CDX OTAQ DC FUEL, making sure to select the “Third Party Engineering Review” certification statement checkbox when prompted. 
    • Fill out and submit the ER webform available within CDX OTAQREG.
  • If the PE is NOT associated with the renewable fuel or foreign ethanol producer in CDX OTAQREG with the necessary role and cannot do so in a timely fashion, the following electronic submission method should be followed:
    • Any user with one of the DC FUEL Submitter roles for the producer should upload and submit the ER report in CDX OTAQ DC FUEL. 
    • The PE must mail a one-page wet-ink signed and stamped affidavit to EPA’s mailing address certifying that he or she developed the ER report. Please see the example affidavit on the Guidance Documents page.
    • No later than April 1, 2018, the PE must create a CDX account, become associated with the producer in CDX OTAQREG, and re-submit the ER report in CDX OTAQ DC FUEL, making sure to select the “Third Party Engineering Review” certification statement checkbox when prompted.