We are considering developing a PTD that lists ethanol and denaturant as separate items being transferred. RINs would be generated for the entire volume of denatured ethanol. If, for example, we transfer 950 gallons of ethanol and 50 gallons of denaturant, may we split the gallon- RINs between ethanol and denaturant? Or would we only indicate the number of gallon-RINs associated with the entire volume of denatured ethanol (i.e., 1000 gallons)?

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The RINS should not be split between ethanol and denaturant. Section 80.1153(a) of the RFS rule refers to "the volume of renewable fuel that is being transferred" as necessary information for PTDs. Denatured ethanol is the "renewable fuel" in your example. It would be incorrect to split the RINs between ethanol and denaturant.

This Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (pdf) (59 pp, 228 KB, EPA420-F-08-006, April 2008)