Questions and Answers on the
                  Renewable Fuel Standard Program
                             Assessment and Standards Division
                                       and
                          Compliance and Innovative Strategies Division

                            Office of Transportation and Air Quality
                            U.S. Environmental Protection Agency
v>EPA
United States
Environmental Protection
Agency
EPA420-F-07-041
May 2007

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Introduction

       The final rulemaking for the Renewable Fuel Standard (RFS) program was signed
by the EPA Administrator on April  10, 2007 and published in the Federal Register on
May 1, 2007 [72 FR 23900]. Since the program begins on September 1, 2007, regulated
parties will need to design and implement their information technology  (IT) systems in a
relatively short period of time.  To assist these regulated parties, we have collected
questions pertaining to a variety of implementation issues and generated responses to
those questions. This document was prepared by EPA's Office of Transportation and Air
Quality (OTAQ), and will be updated periodically as new questions arise.

       Regulated parties may use this document to aid in achieving compliance with the
RFS program regulations. However, this document does not in any way alter the
requirements of these regulations. While the answers provided in this document
represent the Agency's interpretation and general plans for implementation of the
regulations at this time, some of the responses may change as additional information
becomes available, or as the Agency further considers certain issues.

       This question and answer document does not establish or change legal rights or
obligations. It does not establish binding rules or requirements and is not fully
determinative of the issues addressed.  Agency decisions in any particular case will be
made applying the law and regulations on the basis of specific facts and actual action.

       While we have attempted to include answers to all of the questions submitted to
us, the necessity for policy decisions and/or resource constraints may have prevented the
inclusion of certain questions. Questions not answered in this document will be answered
in subsequent updates. Questions that merely require a justification of the regulations, or
that have been previously answered in the preamble to the regulations and require no
further elaboration have been omitted.

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Table of Contents

List of Acronyms	4
1.   Valid renewable fuels and Equivalence Values	5
2.   Generating RINs and assigning them to batches of renewable fuel	6
3.   Transferring RINs with renewable fuel	11
4.   Separating RINs from renewable fuel	13
5.   Market for separated RINs	17
6.   Obligated and nonobligated parties	18
7.   Renewable Volume Obligations (RVO)	19
8.   Company and Facility Registration	20
9.   Recordkeeping and Product Transfer Documents (PTDs)	21
10.    Reporting and the EPA's Central Data Exchange (CDX)	23
11.    Other questions	26
12.    Examples of RIN generation, assignment, and transfer	27

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List of Acronyms
BBBBB
BOL
CDX
CFR
E85
ETBE
EV
K
NRLM
PTD
RIN
RR
RVO
YYYY
RIN code identifying the batch number
Bill of lading
Central Data Exchange
Code of Federal Regulations
Blend of 85% ethanol and 15% gasoline
Ethyl tertiary butyl ether
Equivalence Value
RIN code indicating that the RIN is assigned or unassigned
Nonroad locomotive and marine diesel fuel
Product Transfer Document
Renewable Identification Number
RIN code identifying the Equivalence Value
Renewable Volume Obligation
RIN code identifying the year renewable fuel was produced or imported

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1.      Valid renewable fuels and Equivalence Values

1.1     If I have a renewable fuel that was assigned a specific Equivalence Value in
       regulation Section 80.1115, but I don't think that Equivalence Value is right for
       my product, what options do I have?

       A:     Producers or importers of renewable fuel may submit a petition to the
             EPA requesting a different Equivalence Value from that assigned in the
             regulations.  However, the petition must use the calculation methodology
             described in regulation Section 80.1115(d). In short, if the energy content
             or renewable content of a producer's or importer's product differs from
             the values used by EPA to calculate the Equivalence Values specified in
             regulation Section 80.1115(b), the party may be entitled to an alternative
             Equivalence Value.

1.2     I will be making renewable gasoline from renewable crude.  Section
       80.1115(b)(6) of the regulations says I must use an Equivalence Value of 1.0 even
       though renewable gasoline clearly warrants a higher Equivalence Value.  Can I
       submit a petition?

       A:     Yes.  See regulation Section 80.1115(c)(2). However, for renewable fuels
             other than renewable diesel which are made from renewable crudes,
             information on the energy content and/or renewable content may be
             difficult to obtain. This is why we designated the Equivalence Value for
             such fuels as 1.0, and specified that the applicable volumes must be
             measured according to the volume of renewable crude rather than the
             volume of the final product.  In cases where information on the energy
             content and renew able content can be determined precisely, a different
             Equivalence Value may be warranted.

             In addition, regulation Section 80.1126(d)(6) allows a party to petition
             EPA to use the volume of the renewable fuel produced as the basis for
             generating RINs rather than the volume of the renewable crude used to
             make that product.

1.3     What is the Equivalence Value for E85? Is it 0.85 since its renewable content is
       only 85 percent?

       A:     No. Equivalence Values are generated and apply to renewable fuel at the
             point of production or importation, not at the point of blending.  Thus it is
             denatured ethanol, not E85 (nor El0)  to which the Equivalence Value
             applies. A party blending denatured ethanol into gasoline to produce E85
             may receive  assigned RINs with the denatured ethanol. Since the party is
             producing motor vehicle fuel from the renewable fuel (analogous to an
             oxygenate blender),  he will separate the RINs from the volume of ethanol
             received and can then retain or transfer those RINs to any other party.

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2.     Generating RINs and assigning them to batches of renewable fuel

2.1     Ethanol is imported on an undenatured basis. Do we assign the RINs to the
       denatured volume or the undenatured volume?

       A:    Denatured. See regulation Sections 80.1101(d) (3) and 80.1115(b)(2).

2.2     We are importers who import ethanol without denaturant, but with the intent to
       use it as motor fuel.  When the RIN is generated, we maintain ownership of the
       ethanol, but we do not have custody and we  do not add the denaturant.  Would we
       include our company ID number and use the facility number of the denaturing
       facility (i.e. they would have to be registered)?

       A:    The owner of the denaturing facility would not necessarily be a registered
             party under the regulations. The  company and facility IDs of the
             importing party who owns the renewable fuel at the time a RIN is
             generated (based on the volume of renewable fuel with denaturant) are the
             company and facility IDs that must be included in the RIN.  (The owner of
             the renewable fuel should know the volume of the fuel coming out of the
             denaturing facility since it owns and will either sell or use the denatured
             fuel.) The importing company that owns the fuel would need to register
             the facility, typically leased tankage,  with which it has contracted to store
             and denature the renewable fuel (i.e., has custody) as one if its own
             facilities with its own facility ID number. This means that a facility owned
             by a company that simply leases tankage may never be a registered party
             but several registered importers may have a separate facility ID for that
             tankage facility. This scenario would not apply to domestic producers
             because ethanol intended to be used as motor fuel would be denatured at
             the facility where it was produced.

2.3     A refinery can produce non-ester renewable  diesel by processing renewable
       feedstock through a distillate hydrotreater. In this situation, the refinery must
       assign RINs based on the feed volume. I assume the refinery can follow the rules
       for defining a batch (i.e. a batch can be up to the production volume of a month as
       long as the batch total volume is less than 100 million gallons).

       A:    Yes. However, it is the total number  ofgallon-RINs, not the total volume,
             that must be less than  100 million. See regulation Section 80.1126(c).

2.4     When a plant determines the volume of ethanol  for a first and last gallon of a
       RIN, what's the reference point? Gallons at load-out through a metering system
       like Determan Brownie?  (Since this is the point where they're adjusting the
       gallons to 60 degrees F)?

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      A:    Renewable fuel producers and importers have flexibility in terms of the
             specific means through which they measure volumes for purposes of
             generating RINs. However, the approach should ensure that gallons are
             neither systematically ignored nor systematically double-counted. Also,
             approaches that provide consistent volumes for both the RFS program and
             other contexts such as reporting to the Energy Information Administration
             are preferred.  To the degree that measuring volumes at load-out through
             a Determan Brownie metering system meets these criteria, it would be
             acceptable.

             Under the regulations, RINs must be generated for a volume of renewable
             fuel by the time that that volume is transferred to another party (at which
             time, the RINs are "assigned" to the renewable fuel pursuant to
             regulation Section 80.1126(e)(2)). Thus the volume measurement used as
             the basis of RIN generation can occur as the renewable fuel is produced,
             as it resides in a tank awaiting transfer from the producer/importer, or as
             it is pumped to a new owner.

2.5   Within the RIN, D = 2 for non-cellulosic biomass ethanol and D = 1 for cellulosic
      biomass ethanol.  How is biodiesel coded?

      A:    All renewable fuels that cannot be categorized as cellulosic biomass
             ethanol should be assigned RINs with a D code  value of 2. Thus biodiesel
             would have D = 2.  See regulation Section 80.1125(g).

2.6   Can an ethanol or biodiesel plant keep a RIN?

      A:    In general, producers of renewable fuel must assign all RINs that they
             generate to volumes of renewable fuel and transfer those RINs with the
             renewable fuel to another party. However, there are some exceptions.
             First, producers of cellulosic or waste-derived ethanol can retain RINs
             generated in excess of an Equivalence Value of 1.0 (see regulation Section
             80.1126(e)(4)).  Second, a renewable fuel producer who is also an
             obligated party can retain RINs generated up to the level of their annual
             RVO (see regulation Section 80.1129(b)(6)).  Lastly, producers can
             acquire an unlimited number ofunassignedRINs through the open RIN
             market.

2.7   No Equivalence Value was provided for ETBE.  What value do I use for
      generating RINs for ETBE?

      A:    The RFS program prohibits a party from generating RINs if the renewable
             feedstock used to make the renewable fuel was acquired from another party.
             Any RINs acquired with the renewable feedstock (e.g., ethanol) must be
             assigned to the renewable fuel product (e.g., ETBE) made from that feedstock.
             If the ethanol used to make ETBE does not have RINs associated with it (i.e.

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             the RINs have been properly separated prior to receipt of the ethanol by the
             ETBE producer), then the ETBE producer would neither generate RINs for
             the ETBE it producers, nor assign any RINs to that ETBE. Thus there is no
             need for an Equivalence Value for ETBE. See regulation Section
             80.1126(d)(8).

2.8    I will be making ethanol from both cellulosic feedstocks and corn in my plant.
       How do I know what Equivalence Value to use, and how do I assign RINs to
       batches?

       A:    There are two possible ways to address this situation.  If the volume of
             each type of ethanol can be measured independently and precisely (for
             example, in a facility where  the conversion of cellulosic feedstocks to
             ethanol occurs through separate equipment from that used to convert corn
             to ethanol), RINs can be generated separately for each type of ethanol
             with a unique Equivalence Value. The same batch number (RIN code
             BBBBB) can  be used to represent all the gallon-RINs generated, but the
             gallon-RINs representing the cellulosic ethanol will need to be listed
             separately from the gallon-RINs representing the corn-ethanol, since the
             two groups of RINs will have different RR codes (representing different
             Equivalence Values).

             Alternatively, we have created a regulatory mechanism through which the
             producer may submit a petition to the Agency describing the renewable
             fuel, its feedstock and production process, and the calculation of its
             Equivalence Value.  See  regulation Section 80.1115. This petition process
             can be used to identify an appropriate Equivalence Value for mixtures of
             renewable fuels.

2.9    Are RINs generated at the end of the month based on actual quantities for that
       period, or are they  established at the beginning of the month based on estimates of
       production that month (i.e. "x" gallons, and once "x" gallons are exceeded the
       RIN starts over?)

       A:    All RINs represent actual production, not estimates. However, there is no
             need to wait until the end of a month to generate RINs.  Each producer
             and importer should decide what the batch number (the BBBBB code in
             the RIN) will represent.  The regulations require only that each batch
             represent no more than the volume produced or imported within a
             calendar month, and less than 100 million gallon-RINs. One party may
             decide to assign each week's production a unique batch number, while
             another may decide to assign each tankfull a unique batch number.
             Regardless, gallon-RINs can be generated as volumes are produced and
             transferred. As more volume of renewable fuel is produced, additional
             gallon-RINs are generated within the same batch, up to the self-imposed

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             or regulatory limit for that batch. Then a new batch with a new BBBBB
             code begins.

2.10   If a plant establishes RINs at the beginning of the month and defines it as one
       month's production estimate (e.g. 8 million gallons), what happens if the plant
       produces more than 8 million gallons by the end of the month? Does the plant
       then start issuing a new batch number for the next 8 million gallon RIN? What if
       this happens in the middle of filling a rail car?

       A:    RINs are not generated at the beginning of a month. Rather, gallon-RINs
             must have been generated by the time a volume of renewable fuel is
             transferred from the producer or importer to another party (at which point
             the RINs are assigned to that volume). See regulation Section
             80.1126(e)(2). A producer or importer of renewable fuel can decide on its
             preferred approach of designating batch numbers (the BBBBB code in the
             RIN),  and then put this batch number into all gallon-RINs generated up to
             a calendar month's production or 100 million gallon-RINs, whichever
             comes first.

             If a producer/importer had predefined a specific volume limit (such as 8
             million gallons) for each batch, and this limit was exceeded in the middle
             of filling a rail car, the producer/importer would have two options.  Since
             the 8 million gallon limit is self-imposed, he could simply exceed this limit
             for this particular batch. Alternatively, he could generate a new set of
             gallon-RINs having a new batch number for the volume that exceeded 8
             million gallons.  In this latter case, the renewable fuel in the rail car
             would be transferred along with two separate batch-RINs, which differ
             only in the batch number (i.e. the BBBBB code) and the number of gallon-
             RINs they represent.

2.11   Do batch numbers have  to be  sequential? Do they have to correspond to the
       month that they represent (i.e. 1 - 12)?

       A:    Batch numbers need not be sequential and need not represent a full
             month. They need only be unique within a calendar year.  Each producer
             or importer of renewable fuel can define a batch in whatever way it
             chooses,  so long as each batch represents less than 100 million gallon-
             RINs and no more than one calendar month's production.  See regulation
             Sections 80.1125(e) and 80.1126(c). Examples of permissible batch
             numbering schemes include individual tankfulls, calendar day production,
             weekly production, and volume sold to each customer each month.

2.12   When the program starts, will renewable fuels in the distribution system on
       September 1, 2007 be valid for RFS compliance purposes?

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      A:    In some cases, yes. Renewable fuels that are valid for RFS compliance
             purposes are those for which RINs have been generated.  Under
             regulation Sections 80.1104 and 80.1126(d)(l), RINs must be generated to
             represent renewable fuels that are produced or imported on or after
             September 1, 2007. However,  our regulations do not define the point at
             which production occurs.  It could be the point of physical production,
             loading into a tank, or transfer to another party. Thus, under regulation
             Section 80.1126(d)(2), RINs can also be generated for renewable fuel that
             a producer or importer owns on September 1, 2007 even if that renewable
             fuel had been physically produced or imported prior to September 1.
             Since some renewable fuel will be in the distribution system while
             remaining under the ownership of a producer or importer on September 1,
             2007, it may be assigned RINs even though it has already physically left
             the originating production or importation facility. In such cases,
             renewable fuel in the distribution system on September 1, 2007 may have
             assigned RINs.

             Parties other than renewable fuel producers and importers are not
             allowed to generate RINs at any time (including for renewable fuel in the
             distribution system on September 1, 2007).  Renewable fuel producers and
             importers may generate RINs for renewable fuel they own on September 1,
             2007 that was produced or imported earlier, and must generate RINs for
             renewable fuel produced or imported on or after September 1, 2007.

2.13  Can a producer aggregate multiple shipments into a single batch up to a threshold
      quantity as long as the batch is within one calendar month?

      A:    Yes. In the context of generating RINs and specifying the BBBBB code,
             producers and importers have  the option to define a batch as being
             comprised of several discreet shipments within a calendar month, so long
             as the total number of gallon-RINs assigned a unique batch number is less
             than 100 million. See regulation Sections 80.1125(e) and 80.1126(c).

2.14  When is a RIN generated for ethanol that is imported into the U. S.?

      A:    Ethanol imported for use as motor vehicle fuel would typically be
             downloaded from a ship into on-shore tankage and then denatured.
             (Ethanol shipped to the United States from other countries is not typically
             denatured prior to or during shipment.)  Importers should generate RINs
             for imported ethanol when the  denaturant is added at the off-loading
             tankage. Thus, the facility number used to create these RINs would be the
             tankage facility where the denaturant is added. See also question 2.2.

2.15  Regulation Section 80.1126(d)(l), which says "must," seems in conflict with
      Section 80.1126(d)(2) which says "may". Is the correct reading that any volume
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       of renewable fuel that leaves a producer's gate on or after 9/1/07 MUST have
       RINs assigned?

       A:    Renewable fuel producers and importers may generate RINs for
             renewable fuel they own on September 1, 2007 that was produced or
             imported earlier, and must generate RINs for renewable fuel produced or
             imported on or after September 1, 2007. Thus at the beginning of the
             program, it is possible that some volumes of renewable fuel being
             transferred by a renewable fuel producer or importer may not have
             assigned RINs. However, this will not be the case in the longer term,
             since all renewable fuel imported or produced must have assigned RINs.

2.16   What's the difference between generating a RIN and assigning it?

       A:    Generating a RIN refers to the process of creating a new RIN to represent
             a particular type and volume of renewable fuel.  See regulation Section
             80.1126(d).  Assignment occurs when the producer or importer of the
             renewable fuel transfers a RIN to another party along with a volume of
             renewable fuel. See regulation Section 80.1126(e).

             Note that the regulations do not specify the point when generation of RINs
             must occur.  Under regulation Section 80.1126(e)(2), it is only at the point
             when a volume of renewable fuel leaves the production or importation
             facility where it originated that RINs must have been generated for,
             assigned to,  and transferred with that volume. Since the EPA does not
             specifically define the point of production or importation, a producer can
             generate RINs as the renewable is being physically produced, as it sits in
             a tank awaiting transfer to another party, or even while the renewable fuel
             is  being transferred to another party.
3.      Transferring RINs with renewable fuel

3.1     The final rule on page 23909 (Federal Register, volume 72) states that any non-
       obligated party that takes ownership of the renewable fuel with RINs will be
       required to transfer those RINs with a volume of renewable fuel. Does this refer
       to oxygenate blenders?

       A:     No, as long as the blender actually blends the renewable fuel into gasoline
             or diesel. In that case, the blender would be required to separate the
             assigned RINs from the blended renew able fuel, and could then transfer
             the RINs to any party without simultaneously transferring a volume of
             renewable fuel. See regulation Sections 80.1128(a)(3)  and 80.1129(b)(2).
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3.2    If an oxygenate blender must transfer RINs with a volume of renewable fuel, who
       are they transferring to, if they are the final/end-user?

       A:    If cmy oxygenate blender blends renewable fuel into gasoline or diesel, he
             is no longer required to transfer RINs and renewable fuel together.

3.3    Do third party marketers like Provista need to track RINs from the ethanol plant
       to the buyer?

       A:    If Provista takes ownership of ethanol along with assigned RINs, it would
             be required to register with the EPA and would be subject to the
             recordkeeping and reporting requirements of regulation Sections
             80.1151(d) and 80.1152(c). The tracking required under the RFS rule
             involves only transfers of title (ownership), not transfers of custody. If
             Provista never takes ownership  of ethanol with assigned RINs and does
             not participate in other ways in  the RFS program (for example, through
             the purchase and sale ofunassignedRINs), it would not be required to
             register with, or report to, EPA  under the RFS program.

3.4    Will ethanol and biodiesel plants have to track the RIN all the way to the refiner,
       or just to the next owner of the renewable fuel?

       A:    See previous question and answer. Each party that owns assigned or
             unassigned RINs, including an ethanol or biodiesel production plant, is
             required only to keep records of and report transfers of ownership of those
             RINs to the next owner.  See regulation Sections 80.1151 and 80.1152.

3.5    The RIN is too long to fit onto my bill of lading. What are my options?

       A:    An assigned RIN must appear in its entirety on product transfer
             documents (PTDs) identifying a transfer of ownership of a volume of
             renewable fuel. Substitute codes are not permitted.  See regulation
             Section 80.1153. (In general PTDs would not include bills-of-lading,
             which are used for transfers of custody rather than transfers of
             ownership.) However, the PTD transferring the RINs can be a separate
             and par allel PTD from  that used to transfer the renewable fuel to which
             those RINs are assigned. In this case, the PTD transferring the renewable
             fuel must include the number of gallon-RINs being transferred and a
             unique reference to the PTD which is transferring the assigned RINs, but
             neednot list the actual RINs.  See regulation Section 80.1153(a)(5)(ii).
             PTDs can be electronic, including computer spreadsheets.

3.6    How do owners of the ethanol account for product samples taken at the plant and
       downstream relative to RINs?  Likewise, how is standard product shrinkage (i.e.
       when ethanol is transferred to a terminal) handled relative to RINs?
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       A:    In general, the RINs associated with small volumes removed for sampling
             and testing, or lost due to evaporation, leakage, or metering imprecision,
             remain valid for RFS compliance purposes.  Small volume losses can be
             accommodated through the regulatory provision which allows up to 2.5
             gallon-RINs to be transferred with each gallon of renewable fuel. See
             regulation Section 80.1128(a)(4). For larger volumes losses resulting
             from spills or other accidents, a provision exists for retiring the associated
             RINs.  See regulation Section 80.1132.

3.7    How does a marketer split RINs that go to downstream buyers (i.e. next owners
       like a refiner)?

       A:    Parties such as marketers that are required to transfer assigned RINs with
             renewable fuel are not required to align the number of gallon-RINs
             transferred with the number of gallons transferred for every transaction.
             Rather, the regulations require only that the number of assigned gallon-
             RINs (with a K code of 1) transferred with each gallon of renewable fuel
             be no more than 2.5.  See regulation Section 80.1128 (a) (4) and preamble
             discussion at page 23939, column 3. Within this limit, a marketer is free
             to allocate gallon-RINs to volumes of renewable fuel in whatever way he
             chooses,  so long as an end-of-quarter check on the balance of RINs versus
             renewable fuel in inventory is met.  See regulation Section 80.1128(a)(5).
4.     Separating RINs from renewable fuel

4.1     Does blending biodiesel into agricultural diesel (or other nonroad diesel such as
       NRLM diesel) allow the RIN to be separated?

       A:    EPA believes that most fuel that can be used as motor vehicle fuel and
             which otherwise meets the definition of "renewable fuel" (such as
             biodiesel and ethanol) will ultimately  be used as motor vehicle fuel.
             Therefore, producers of such products can assume that they meet the
             definition of "renewable fuel"  andean assign RINs to them without
             tracking their ultimate use.

             However, if fuel with assigned RINs is actually blended into gasoline or
             diesel that is known to be destined for use in a nonroad application such
             as agricultural equipment, the presumption that led the fuel producer to
             assign RINs to the product is no longer valid.  Such fuel cannot be
             considered a motor vehicle fuel and thus is not in fact a "renewable fuel"
             that is valid for RFS compliance purposes. In such cases, the blender
             should treat the RINs associated with  the blended fuel in the same way as
             for fuel with assigned RINs that is used in a heater or boiler (see question
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             4.2).  See also preamble Section III.B.I and Summary and Analysis of
             Comments Sections 3.1.2 and 3.1.4.

4.2    If renewable fuel is produced and sold as motor vehicle fuel, what happens if it is
       actually used in a heater or boiler?

       A:    Renewable fuel is defined as "motor vehicle fuel, " so does not include fuel
             used in heaters and boilers. However, due to the operation of reasonable
             presumptions, RINs may be generated for fuel that is ultimately used in a
             heater or boiler, and use of those RINs for compliance purposes depends
             on the circumstances.

             If a producer or importer transfers fuel to another party with the intent or
             expectation  that it will be used in a boiler or heater, the producer or
             importer cannot generate RINs for that volume. Likewise, fuel used
             onsite in a boiler or heater by a renewable fuel producer or importer is
             not a renewable fuel in the context of the RFS program, and thus no RINs
             can be generated for that volume.

             However, if a producer or importer transfers fuel to another party with
             the intent or expectation that it will be used as a motor vehicle fuel, and
             such fuel otherwise meets the definition of "renewable fuel, " RINs will
             legitimately be generated to represent that volume. Nevertheless, it is
             possible that the fuel would subsequently be used in a heater or boiler.
             Since fuel used in heaters and boilers is not considered motor vehicle fuel
             or, therefore, renewable fuel,  in general the RINs generated to represent
             that fuel should be not be used for RFS compliance purposes. If the party
             who used the renewable fuel in a heater or boiler did not receive  RINs
             with the renewable fuel (for example, if RINs were separated from the fuel
             upstream), we would not require any further action from the party who
             used the renewable fuel in a heater or boiler and the separated RINs could
             be used for compliance purposes by the upstream party that separated
             them or to whom they were transferred, provided that they were not aware
             that the fuel would ultimately be used in a heater or boiler. However, if
             the party that used the fuel in a heater or boiler received assigned RINs
             with that fuel, the party cannot use the RINs for compliance purposes or
             transfer those RINs to any other party.  Such RINs would be  considered
             "invalid" under regulation Sections  80.1131(a)(6) and 80.1101(d)(5).

4.3    Can an oxygenate blender separate RINs from batches of renewable fuel and
       participate in trading?

       A:    Yes, if the blender actually blends renewable fuel that it owns into
             gasoline or diesel. Separated RINs then become  unassigned RINs that can
             be traded without renewable fuel.  See regulation Section 80.1129(b)(2).
             See also questions 3.1 and 3.2.
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4.4    A refinery can produce non-ester renewable diesel by processing renewable
       feedstock through a distillate hydrotreater.  In this situation, the refinery must
       assign RINs based on the feed volume. The refiner is then both an obligated party
       and a renewable fuel producer and as such can separate the RIN immediately.  Is
       this correct?

       A:    Yes, since under regulation Section 80.1129(b)(l) all obligated parties
             must separate RINs from batches they own. However, an obligated party
             can only separate RINs that it generates from volumes of renewable fuel if
             the number of gallon-RINs separated is less than or equal to its annual
             RVO. See regulation Section 80.1129(b)(6).

4.5    Do we have to keep some type of spreadsheet listing the assigned RINs and  the
       "flipping" of the K code to designate that we stripped them?

       A:    Under the regulations at Section 80.1151, a party that separates RINs
             from volumes of renewable fuel is subject to certain recordkeeping
             requirements.  There is no specific recordkeeping requirement to show the
             timing or conditions under which the K code for a RIN was changed from
             1 to 2.  However, RINs received with a K code of 1 that were separated by
             a party should be  reported with K codes of 2.  The format of records (e.g.
             spreadsheets versus paper records) is left to the discretion of the party.

4.6    Since they receive 1.5 RINs per gallon, can a biodiesel plant separate the RIN
       from a physical gallon?

       A:    No. Producers and importers of renewable fuel must assign all RINs
             generated to renewable fuel, and transfer those RINs when transferring
             volumes of renewable fuel to another party. See regulation Section
             80.1126(e)(l).  There are limited exceptions to this rule that do not apply
             to biodiesel.  See  regulation Section 80.1126(e)(4) and response to
             Question 2.6.

4.7    I am a small refiner who is exempt from meeting the standard. Am I allowed to
       separate RINs from batches of renewable fuel?

       A:    Exempt small refiners and refineries are not obligated parties. As a
             result, they cannot separate assigned RINs from volumes of renewable fuel
             upon ownership of the renewable fuel. However, if the exempt small
             refiner/refinery blends renewable fuel into gasoline or diesel, they are
             operating as a blender andean separate the RINs associated with the
             renewable fuel added to the blended product. A small refiner/refinery that
             waives its exemption becomes an obligated party and must also separate
             assigned RINs from volumes of renewable fuel upon ownership.
                                       15

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4.8    If I import ethanol for someone else, and they blend the ethanol into gasoline, do I
       get the RINs?

       A:    In general, all rights and responsibilities under the RFSprogram that are
             tied to renewable fuel are based on ownership of fuel, not custody. Thus if
             you own the ethanol even though another party blends it into gasoline,
             then you would separate the RINs associated with the ethanol and would
             retain or transfer them to another party depending on the situation. If,
             however, your involvement was only to physically supply the ethanol while
             never taking ownership of it, then you would not own the RINs and could
             not separate them upon blending - that would be the responsibility of the
             owner of the ethanol.

4.9    At our terminal, we transfer ownership of ethanol to our customers
       simultaneously with blending that ethanol into gasoline. Who owns the RINs?

       A:    A RIN assigned to a volume of renewable fuel is separated by the party
             that owns  that volume of renewable fuel at the time of blending.  If a
             downstream customer is  the owner of the volume of renewable fuel when it
             is  blended into gasoline or diesel, he will own the separated RINs and be
             subject to  all the registration, recordkeeping, and reporting requirements.
             In the case of a blender and a downstream customer who might both lay
             claim to the right to separate any assigned RINs, these two parties would
             need to  come to agreement between themselves regarding which party will
             own the separated RINs.

4.10   Are refiners required to separate RINs from renewable fuel?  If a refiner doesn't
       want the RINs,  why can't he just let the blender have them?

       A:    Obligated parties are required to separate a RIN from a volume of
             renewable fuel if they take ownership of that volume.  See regulation
             Section  80.1129(b)(l) and the limited exception in regulation Section
             80.1129(b)(6). The requirement to separate RINs, rather than merely
             giving obligated parties the right to separate RINs, is intended to promote
             the availability of RINs on the open RIN market. Given that most ethanol
             is  consumed in the midwest, the program is intended  to promote access to
             RINs by obligated parties elsewhere that may lack access to renewable
             fuel.

             An obligated party that separates a RIN from a volume of renewable fuel
             has the option  of transferring that RIN to a blender in parallel with a
             transfer of renewable fuel. However, in this case, the RIN would be an
             unassigned RIN with a K code of 2, and would be transferred on a PTD
             separate and independent from that used to transfer the renewable fuel.
                                       16

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5.      Market for separated RINs

5.1     Will non-obligated parties in possession of RINs create a RIN shortage?

       A:     The in-use production volumes of renewable fuel are expected to exceed
              the requirements of the RFSprogram by a substantial margin. As a result,
              we expect there to be a surplus of RINs for at least the first few years of
              the program, and this surplus means it is highly unlikely that non-
              obligated parties could acquire and retain enough RINs to cause a
              shortage.  In addition, we expect refiners and other obligated parties to
              take ownership of renewable fuel with assigned RINs directly from
             producers in a majority of cases. Nevertheless, EPA will monitor
             program implementation to ensure that RINs that have been generated are
              making their way to the obligated parties that need them.

5.2     If blenders either opt not to trade or are not allowed to trade, who will be
       responsible for tracking these RINs through the system?

       A:     The blender must submit quarterly RIN transaction reports to EPA that
              will document all RIN transactions, including RIN purchases, RIN sales,
              and expired RINs.  RINs that are reported purchased and thereafter are
              not sold will be identifiable through these reports. See regulation Section
              80.1152(c).

5.3     Which non-obligated parties are allowed to participate in the credit trading
       program?  Producers (with extra value RINs), oxygenate blenders, marketers?

       A:     Anyone can participate in the RIN trading program, subject to the
              requirement that the party first register with the EPA and then adhere to
              other regulatory requirements, including submitting required reports
              (such as quarterly reports on RINs held).

5.4     Can RINs at a plant expire?  Or does expiration only refer to RINs held by
       obligated parties?

       A:     Expiration of a RIN is tied only to the amount of time that has elapsed
              since it was generated, not who owns the RIN.  RINs are valid for
              compliance purposes for the compliance year in which they were
              generated (i.e. the YYYY code in the RIN) or the follow ing year. No
              matter who owns a RIN at the end of its valid life, it expires if it is not used
             for compliance purposes for the year generated or the follow ing year. See
              regulation Section 80.1127(a)(3). But in general, since non-obligated
             parties must transfer assigned RINs with renewable fuel (see regulation
              Section 80.1128(a)(3)), it is expected that most RINs that expire will do so
                                       17

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             in the hands of obligated parties and renew able fuel blenders.  See
             regulation Section 80.1127(a)(3).

5.5    A RIN generated in 2007 is valid for compliance purposes for both 2007 and
       2008, but obligated parties are given until February, 2009 to demonstrate
       compliance for 2008.  How do they use a 2007 RIN that expired at the end of
       2008 for compliance purposes if they don't acquire that 2007 RIN until January of
       2009?

       A:    The expiration date of a RIN refers only to the calendar year for which it
             can be used for compliance.  There is no limitation or expiration date for
             trading purposes other than the deadline for the obligated party's annual
             compliance demonstration report.  Thus a RIN generated in 2007 can
             continue to be  traded in 2009, but if acquired in 2009 by an obligated
             party it could only be used for a 2008 compliance demonstration.

5.6    Who reports expired RINs?

       A:    Every party must report RINs owned that have expired as of the end of the
             fourth quarter  of each year.  This report is due  on February 28 of the
             following year and will identify RINs that expired in the fourth quarter of
             the previous calendar year.  Since RINs always expire at the end of a
             calendar year,  all expired RINs will be reported.

             Since obligated parties have until February 28  to submit their annual
             compliance demonstrations  to EPA (or, for 2007 compliance only, May
             31), we allow RINs to be traded between January 1 and February 28 even
             if they were generated two year previous. This means that RINs that are
             reported by a party as expired on December 31 can still be transferred to
             another party after December 31. Designating a RIN as expired is only a
             means of categorizing the RIN and does not mean that the RIN has been
             relinquished, frozen,  or surrendered to the EPA.  Since this requirement
             may cause some confusion, we  intend to promulgate a technical correction
             to the RFS rule to eliminate  the requirement that RINs be reported as
             "expired."
6.      Obligated and nonobligated parties

6.1     Are gasoline blenders no longer considered obligated parties?  I have seen
       references to gasoline refiners and importers. (Of course, gasoline refiners may
       also serve as blenders).

       A:    The regulatory definition of a refiner includes gasoline blenders. Any
             party that produces gasoline from non-renewable feedstocks or
                                       18

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             blendstocks is an obligated party under the RFS program. This would
             include gasoline blenders unless their sole activity is adding renewable
             fuels to conventional gasoline. See regulation Sections 80.1106(a)(l) and
             80.1107(d)(l).

6.2    I am a small volume renewable fuel producer, and so should be exempt from the
       requirement to generate RINs and assign them to renewable fuel that I produce.
       Do I need to submit a form to EPA proving that I produce less than 10,000
       gallons a year?

       A:     No. Small volume producers are automatically exempt.  How ever, if a
             small volume producer chooses to register as a renewable fuel producer
             under the RFS program, they will be subject to all the regulatory
             provisions that apply to all renewable fuel producers, including the
             requirement to assign RINs to batches. See regulation Section 80.1126(b).

6.3    Who is a renewable fuel producer? Will the EPA recognize ethanol marketing
       companies as producers? Can the term "producer" apply to a marketing company
       who represents various producing plants?

       A:     Renewable fuel producers are parties that produce renewable fuel (i. e.
             convert a renewable feedstock into a renewable fuel).  RINs must be
             generated by the producer and assigned to renewable fuel by the time title
             to the renewable fuel is transferred from the producer to another party
             such as a marketer. See regulation Sections 80.1126(d)(l) and (e)(2).  In
             turn, the marketer must transfer assigned RINs to the party to whom the
             marketing company sells the ethanol.

             Marketing companies who "represent" renewable fuel producers are not
             producers unless the marketing company produces renewable fuel, and
             such a company would only generate RINs for that part of the renewable
             fuel that they actually produced.  Ethanol marketing companies that do
             not produce or import renewable fuels are not renewable fuel producers
             or importers and cannot generate RINs.
7.      Renewable Volume Obligations (RVO)

7.1     If a specific refinery is the producer of renewable diesel, I assume they need a
       facility ID number, but we can use the RINs for aggregate company compliance.

       A:    Yes.  The facility ID number is used to generate the RIN, but the RIN can
             be separated and used for compliance on a company-wide aggregate
             basis, subject to any applicable restrictions in the regulations such as
             regulation Sections 80.1106(c) and 80.1129(b) (6).
                                       19

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7.2    If an ethanol producer imports a truckload of gasoline, they are an obligated party
       and have an RVO. Does this mean that they can separate RINs from all the
       ethanol they produce?

       A:    Not necessarily.  Obligated parties can only separate RINs they generated
             for renewable fuel they produced or imported up to the level of their RVO.
             They are not allowed to separate additional RINs that they generated.
             However, obligated parties must separate all RINs from renewable fuel
             that they own if they did not generate those RINs. See regulation Sections
             80.1129(b)(l) and (b)(6).

7.3    Who actually calculates  the RVO? The refinery or EPA?

       A:    Each obligated party calculates the RVO itself, based on its annual
             gasoline volume. See regulation Sections 80.1152(a)(l)(v) and (vi).

7.4    CARBOB doesn't appear in the list of fuels comprising the RVO
       (regulation Section 80.1107). However, in the Preamble, EPA mentions RBOB
       and CBOB.  Is CARBOB considered a subset of RBOB?

       A:    The regulations include in the list of products to be included in the volume
             used to calculate the RVO "Any gasoline, or any unfinished gasoline that
             becomes finished gasoline upon the addition of oxygenate, that is
             produced or imported to comply with a state or local fuels program. "
             CARBOB would fall under this category.  See regulation Section
             80.1107(c)(6).
8.      Company and Facility Registration

8.1     When will the EPA registration forms be ready to obtain the plant and facility ID
       numbers?

       A:    Registration forms may be submitted any time after May 1, 2007, the
             publication date of the final RFS rules.  See regulation Section
             80.1150(a).  Registration forms and instructions are linked to our RFS
             page at http://www.epa.gov/otaq/renewablefuels/. Potential registrants
             can fill the form out on the web site, submit it electronically to EPA and
             print out a copy which then must be signed by the responsible corporate
             officer and sent to EPA (directions for sending are on the forms).  When
             EPA receives the signed copy of the registration, EPA will email the
             registrant with confirmation of registration and an appropriate ID
             number.
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8.2    If my company and facilities are already registered with EPA under another
       program, do I have to register for RFS?

       A:    No, but you are responsible for updating your company or facility
             information within 30 days of a change. See regulation Section
             80.76(e)(l).  Registration forms and instructions are linked to our RFS
             page at http://www.epa.gov/otaq/renewablefuels/.

8.3    If my company or facility information changes, how do I correct that in the EPA
       registration system?

       A:    You are responsible for notifying EPA of any changes to your information.
             You may do so by filing the online registration form indicating that you
             are updating an existing registration, and mailing a printed copy of the
             form to the EPA.

8.4    How will I know that my registration has been processed by EPA?

       A:    EPA will provide you with company and facility ID numbers after we have
             received a mailed copy of your registration form(s).  Since you need these
             numbers prior to engaging in transactions involving RINs, it is advisable
             to register as early as possible.

8.5    Will third party marketers have different registration forms to complete than
       producers?

       A:    No.  The registration form for third party marketers is the same form as
             the producer registration form.  However, third party marketers are only
             required to obtain an EPA company identification number and not a
             facility identification number.

8.6    Could a marketing company register as a producer with the EPA to represent
       multiple plants?

       A:    No. Each renewable fuel producer must register and is responsible for
             generating RINs (with an  exception for some producers/importers that
             produce or import less than 10,000 gallons of renewable fuel each year).
9.      Recordkeeping and Product Transfer Documents (PTDs)

9.1     How is a Product Transfer Document defined? Must it be an invoice, bill of
       lading (BOL), or can it be either?
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      A:    The regulations do not specify the form of a product transfer document
             (PTD), but do include a list of information that must appear on the PTD.
             See regulation Section 80.1153(a). In the context of the RFSprogram,
             PTDs must identify a transfer of ownership of a volume of renewable fuel.
             In general this would mean invoices. PTDs would in most cases not
             include a bill of lading, which is used primarily for a transfer of custody
             rather than a transfer of ownership.

9.2   As RINs are transferred, do they have to be attached to a PTD (i.e. printed on a
      BOL), or can they be transferred in an electronic spreadsheet that references a
      PTD?

      A:    The RIN must appear in its entirety on PTDs identifying a transfer of
             ownership of a volume of renewable fuel. (In general PTDs would not
             include BOLs, which are used for transfers of custody rather than
             transfers of ownership.) However, the PTD transferring the RINs can be a
             separate and parallel PTD from that used to transfer the renewable fuel to
             which those RINs are assigned. PTDs can be electronic, including
             computer spreadsheets. See regulation Section 80.1153(a)(5).

9.3   If I am an oxygenate blender who  purchases directly from a renewable fuels
      producer, RINs are transferred with ownership of the batch. Therefore, I will be
      in possession of the RINs. How will these RINs be accounted for in my records?

      A:    You must keep a database of all RINs that you take  ownership of at any
             time during a compliance period,  and report those RINs to EPA quarterly.
             See regulation Sections 80.1151(d) and80.1152(c).

9.4   The regulations  at Section 80.1151(b)(5) say that producers must keep "records
      related to the production or importation of renewable fuel that the renewable fuel
      producer or importer designates as motor vehicle fuel and the use of the fuel as
      motor vehicle fuel."  What does this mean?

      A:    This requirement is limited to cases in which a producer or importer
             wants to separate assigned RINs from a volume of renewable fuel under
             the provisions at regulation Section 80.1129(b)(4).  If the renewable fuel
             that the producer or importer produces or imports can be used in its neat
             (unblended) form, it can be designed a motor vehicle fuel without being
             blended with conventional gasoline or diesel. In order to claim the right
             to separate the RINs that have been generated and assigned to such fuel,
             the producer or importer must retain records demonstrating that the
             renewable fuel has been used as motor vehicle fuel in its neat form.

9.5   Can RIN tracking and transfer be handled completely electronically? If so, can
      we choose the software and the report format?
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      A:    You may keep the records in any format you wish.  How ever, you must be
             able to provide readable copies to EPA representatives upon request and
             you must retain records and the means to read them for at least five (5)
             years. You must either be able to convert the records to a readable format
             or provide them in a usable electronic or paper format as requested by
             EPA. (For the purpose of reporting, you may use any commercially
             available format or comma delimited-text. Please refer to Section 10 of
             this Q&A document - Reporting and the EPA 's Central Data Exchange.)
             Note that on product transfer documents (PTDs) (which are required
             when ownership  of a renewable fuel is transferred to another party),
             certain information may be conveyed to some parties through the use of
             product codes; however, information regarding assignedRINs transferred
             with the renewable fuel must always be included on the PTDs.  See
             regulation Section 80.1153(a)(5) and (b).

9.6   If there's a partial gallon on the BOL, how do companies handle rounding when
      tracking RINs?

      A:    The number of assigned gallon-RINs being transferred by parties other
             than renewable fuel producers or importers need not correspond exactly
             to the number of gallons being transferred.  See regulation Section
             80.1128(a)(4). Thus  in general the presence of a partial gallon on aPTD
             will not affect the tracking of RINs. For producers and importers of
             renewable fuel who are required by regulation Section 80.1128(a)(6) to
             transfer a specified number of gallon-RINs with each gallon of renewable
             fuel, partial gallons can be rounded to the nearest whole gallon so long as
             the number of renewable fuel gallons is consistent with the number of
             gallon-RINs.
10.    Reporting and the EPA's Central Data Exchange (CDX)

10.1   Is the RIN transaction report tracked daily but reported quarterly?

       A:    With regard to reporting to EPA, each RIN transaction (i.e., RIN sale or
             purchase, retired or expired RIN) must be reported on a separate RIN
             transaction report.  The RIN transaction report for each transaction must
             be submitted to EPA by the end of the second month after the quarter in
             which the transaction occurred.  See regulation Section 80.1152(c)and
             (d). The reports for RIN transactions that occurred within a quarter may
             be submitted all together, individually, or in groups at any time, so long as
             the transaction reports for all transactions that occurred during the
             quarter are submitted to EPA by the end of the second month after the
             quarter in which the transactions occurred. With regard to transfer of
             RINs between parties, such transfers must be included on some type of
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             product transfer documentation as explained in the section of this
             document dealing with Recordkeeping and Product Transfer Documents
             (PTDs).

10.2  For parties that take ownership of assigned RINs and then separate them, do they
      report those RINs with K code of 1 or 2?

      A:     The regulations state that, in most cases, (1) a party that is an obligated
             party must separate any RINs that have been assigned to a volume of
             renewable fuel if they own that volume, (2) any party that owns a volume
             of renewable fuel must separate any RINs that have been assigned to that
             volume once the volume is blended with gasoline or diesel to produce a
             motor vehicle fuel, and (3) the party responsible for separating a RIN
             from a volume of renewable fuel shall change the K code in the RIN from
             a value of 1 to a value of 2 prior to transferring the RIN to any other
             party.

             In the case of an obligated party, Company A,  that has accepted a volume
             of renewable fuel with an assigned RIN, Company A must change the K
             code from 1 to 2.  However, in a transaction report filed by Company A
             concerning receipt of the RIN,  the RIN would be reported with a K code of
             1 (i.e., as it was received). If the RIN is transferred to another party by
             Company A during the reporting period, Company A  would report the RIN
             on a transaction report for that transfer with a K code of 2.  If the RIN was
             used for compliance, Company A would report the RIN with a K code of 2
             on its annual compliance report.

             In the case of a blender, the RIN would be reported with a K code of 1 for
             the transaction relating to the receipt of the  renewable fuel. After the
             blender blends the renewable fuel into motor vehicle fuel, the RIN would
             be reported with a K code of 2 for a  transaction relating to the transfer of
             the RIN to another party.

             In EPA 's reporting instructions, it will be made clear how a party should
             report the K code for any given report.

10.3  What is the process to retire a RIN? Is this a reporting function that is done with
      the EPA?

      A:     RINs are retired for reasons specified in the regulations  and must be
             reported to EPA. A retired RIN may not be used for compliance purposes
             or traded to another party.  A retired RIN is reported to EPA in a RIN
             transaction report and the total number of RINs retired during a quarter is
             reported to EPA in the gallon-RIN activity report. A  RIN transaction
             report that reports a retired RIN must describe the reason for retiring the
             RIN. Potential reasons include reportable spills under regulation Section
                                       24

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             80.1132, import volume corrections under regulation Section
             80.1166(e)(2), renewable fuel used in boiler or heater under regulation
             Section 80.1129(e), RINs that are invalid (other than expired RINs) or
             RINs required to be retired in the context of an enforcement action. For
             reporting requirements, see regulation Section 80.1152.

10.4  I haven't seen a reference to the EPA CDX system. Is the CDX system already
      established or can we submit reports in our choice of electronic formats?

      A:     The Central Data Exchange (CDX) is an established portal through which
             electronic data are submitted. All registered parties will have to first
             register with CDX in order to receive a CDX registration number.  A link
             to the CDX web site will be provided from our RFSweb site at
             http://www. epa.gov/otaq/renewablefuels. RFS reports can be produced by
             vendor software or by using spreadsheet templates or other data templates
             following instructions linked to the RFSweb site.

10.5  Do I have to register to use CDX and is this a separate registration process?

      A:     You will have to register with CDX.  (Registering with CDX is not the
             same as registering under regulation Section 80.1150.)  Instructions are
             available via our RFS web page at
             http://www.epa.gov/otaq/renewablefuels/.
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11.     Other questions

11.1    What entity retires the RIN if the same RIN is transferred to two or more parties?
       Does the plant retire the RIN? Does the EPA have to be notified?

       A:     Where a RIN is invalid because the same RIN was transferred to two or
             more parties, all such RINs are deemed invalid unless EPA determines
             that some portion of them is valid.  See regulation Section 80.1131(b)(4).
             In the absence of such determination by EPA, all parties with such RINs
             must under regulation Section 80.1131(b)(2), adjust their records, reports
             and compliance calculations as necessary to reflect the deletion of the
             invalid RINs.  "Deletion " refers to annual compliance reports since an
             invalid RIN cannot be used to show compliance. In the case of RINs
             transferred to two or more parties, all such RINs typically should be
             reported as retired unless EPA determines that some portion of them are
             valid.

11.2    Regulation Section 80.1131 (b)(4) states that, in the event that the same RIN is
       transferred to two or more parties, "all such RINs will be deemed to be invalid,
       unless EPA in its sole discretion determines that some portion of these RINS is
       valid". What's the process to determine if a portion of RINs are valid?

       A:     In many circumstances, EPA will be able to determine whether any of the
             RINs (or particular gallon-RINs within a batch-RIN) are valid from the
             information submitted to EPA in the RIN generation and transaction
             reports.  Through these reports, it is possible to track a RIN from the point
             of generation by the renewable fuel producer or importer through each
             transaction until the RIN is used for compliance, retired or has expired. If
             EPA determines that a RIN is invalid, EPA would contact the submitter of
             the report(s) with the invalid RIN and advise the party how to proceed.

11.3    If a party buys a batch of ethanol, and through testing determines that the ethanol
       is synthetic (non-renewable), what happens to the RINs?

       A:     If a volume of renewable fuel for which RINs have been generated is found
             to not be a valid renew able fuel under the RFS program, then the
             associated RINs are likewise deemed invalid. See regulation Section
             80.1131. If a party determines that a batch of fuel that they own does not
             meet the definition  of renewable fuel under the RFS program, the RINs
             received with such fuel must be deleted from records, reports and
             compliance demonstrations.  See regulation Section 80.1131. In general,
             RINs received with such fuel must be reported as retired and such invalid
             RINs must be deleted from any compliance reports.  Parties that learn of
             such a situation should promptly inform EPA. EPA will investigate the
             source of the fuel and take appropriate action.
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 11.4   What metering system does the plant use to measure gallons? Is it a production
       meter, a load-out meter, etc.?

       A:    EPA regulations provide flexibility in terms of the specific mechanisms
             through which producers and importers measure volumes for purposes of
             generating RINs. However, the approach should ensure that gallons are
             neither systematically ignored nor systematically double-counted. Also,
             approaches that provide consistent volumes for both the RFS program and
             other contexts such as reporting to the Energy Information Administration
             are preferred.
 12.    Examples of RIN generation, assignment, and transfer

 All examples use fictional names, company IDs, and facility IDs.
 Example RIN codes have been separated by hyphens for clarity.
 12.1   Examples of renewable fuel producers and importers

 Example A-l	
 September 1: Producer Jones makes 2000 gallons of denatured ethanol from corn in
       2007. He stores all 2000 gallons in a tank.
 September 2: Producer Jones generates 2000 gallon-RINs to represent the 2000 gallons.

       Equivalence value of 1.0 x 2000 gallons = 2000 gallon-RINs
       Batch-RIN: 1 -2007-1234-12345-00001 -10-2-00000001 -00002000

 September 3: Producer Jones sells 2000 gallons to Marketer Smith.
       Producer Jones uses a single PTD to transfer the volume and also transfer
	assigned 2000 gallon-RINs, summarized in a single batch-RIN.	
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 Example A-2	
 September 4: Producer Jones makes another 3000 gallons of denatured ethanol from
       corn in 2007. As the ethanol is being metered into a tank, he generates 3000
       gallon-RINs to represent the 3000 gallons.

       Equivalence value of 1.0 x 3000 gallons = 3000 gallon-RINs
       Batch-RIN: 1-2007-1234-12345-00001-10-2-00002001-00005000

 September 5: Producer Jones sells 1000 gallons to Marketer Smith.
       Producer Jones uses a PTD to transfer the volume, indicating that 1000 assigned
       gallon-RINs will be transferred in parallel, and containing a unique reference to
       another PTD.
       Producer Jones sends a spreadsheet as the parallel PTD to Marketer Smith later
       on the same day, transferring batch-RIN 1-2007-1234-12345-00001-10-2-
	00002001-00003000	

 Example A-3	
 September 6: Producer Jones makes another 1000 gallons of denatured ethanol from
       corn in 2007. He stores the 1000 gallons in a tank that already contains 2000
       gallons.
 September 7: Producer Jones sells 3000 gallons to Marketer Smith.
       As the ethanol is being metered into a railcar, Producer Jones generates 1000
       gallon-RINs under a new batch number to represent 1000 gallons.

       Equivalence value of 1.0 x 1000 gallons = 1000 gallon-RINs
       Batch-RIN: 1 -2007-1234-12345-00002-10-2-00000001 -00001000

       Producer Jones uses a single PTD to transfer the 3000 gallons and also transfer
       3000 assigned gallon-RINs, summarized in two batch-RINs:
              1-2007-1234-12345-00001-10-2-00003001-00005000
              1-2007-1234-12345-00002-10-2-00000001-00001000
                                       28

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 Example B-l	
 September 1: Producer Davis makes 2000 gallons of biodiesel in 2007.
       He stores all 2000 gallons in a tank.
 September 2: Producer Davis makes another 5000 gallons of biodiesel.
       He adds the 5000 gallons to the tank already holding the 2000 gallons.
 September 3: Producer Davis generates 1500 gallon-RINs to represent 1000 gallons.

       Equivalence value of 1.5 x 1000 gallons = 1500 gallon-RINs
       Batch-RIN: 1-2007-4321-12345-00003-15-2-00000001-00001500

 September 4: Producer Davis sells 1000 gallons to Marketer Johnson.
       Producer Davis uses a single PTD to transfer the volume and also transfer 1500
	assigned gallon-RINs, summarized in a single batch-RIN.	
 Example B-2	
 September 5: Producer Davis generates 9000 gallon-RINs under a new batch number to
       represent 6000 gallons of biodiesel that were produced in 2007.

       Equivalence value of 1.5 x 6000 gallons = 9000 gallon-RINs
       Batch-RIN: 1 -2007-4321 -12345-00005-15-2-00000001 -00009000

 September 6: Producer Davis sells 4000 gallons to Marketer Johnson.
       Producer Davis uses a single PTD to transfer the volume and also transfer 6000
       assigned gallon-RINs, summarized in a single batch-RIN:
              1-2007-4321-12345-00005-15-2-00000001-00006000

 September 7: Producer Davis sells 2000 gallons to Marketer Williams.
       Producer Davis uses a PTD to transfer the volume, indicating that 3000 assigned
       gallon-RINs will be transferred in parallel, and containing a unique reference to
       another PTD.
       Producer Davis sends the parallel PTD to Marketer Williams later on the same
       day, transferring batch-RIN 1-2007-4321-12345-00005-15-2-00006001-
       00009000
                                       29

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Example C-l	
September 1: Producer Brown makes 4000 gallons of denatured ethanol from cellulosic
      biomass in 2007. As the ethanol is being metered into a tank, he generates
      10,000 gallon-RINs in two separate batches to represent the 4000 gallons.

      Equivalence value of 2.5 x 4000 gallons = 10,000 gallon-RINs
      First batch-RIN:      1-2007-5678-12345-00001-25-1-00000001-00005000
      Second batch-RIN:   1-2007-5678-12345-00002-25-1-00005001-00010000

September 2: Producer Brown sells 1000 gallons to Marketer Miller.
      Producer Brown uses a single PTD to transfer the volume to Marketer Miller and
      also transfer 1000 assigned gallon-RINs, summarized in a single batch-RIN:
             1-2007-5678-12345-00002-25-1-00006001-00007000
September 3: Producer Brown sells 1500 unassigned gallon-RINs to Broker Wilson
      without ethanol.  The PTD includes the following two batch-RINs:
             2-2007-5678-12345-00001-25-1-00000001-00000700
             2-2007-5678-12345-00002-25-1-00007001-00007800
Example C-2	
September 4: Producer Brown makes 1000 gallons of denatured ethanol from cellulosic
      biomass in 2007. He stores 500 gallons in one tank, and 500 gallons in another
      tank.
September 5: Producer Brown generates 2500 gallon-RINs to represent the 1000
      gallons. He adds the gallon-RINs to a pre-existing batch.

      Equivalence value of 2.5 x 1000 gallons = 2500 gallon-RINs
      Batch-RIN:    1-2007-5678-12345-00001-25-1-00005001-00007500

      Producer Brown sells 2000 gallons to Marketer Miller.
      Producer Brown uses a single PTD to transfer the volume to Marketer Miller and
      also transfer 3000 assigned gallon-RINs, summarized in a single batch-RIN:
             1-2007-5678-12345-00001-25-1-00004501-00007500
                                      30

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 12.2   Examples of marketers and distributors of renewable fuel

 Example D-l	
 September 10: Marketer Moore takes ownership of 5000 gallons of denatured ethanol
       with 5000 assigned gallon-RINs in a single batch-RIN:
              1-2007-8765-12345-00022-10-2-00004055-00009054
 September 15: Marketer Moore sells 3000 gallons of ethanol to Blender Taylor without
       any assigned RINs. The PTD states, "No RINs transferred."
 September 30: Marketer Moore verifies that his end-of-quarter gallon-RINs do not
       exceed his end-of-quarter gallons adjusted for their Equivalence Value.

              5000 gallon-RINs < 2000 gallons x Equivalence Value of 2.5
	5000 gallon-RINs < 5000 gallons (adjusted)	


 Example D-2	
 October 1: Marketer Moore takes ownership of 2000 gallons of biodiesel with 3000
       assigned gallon-RINs in two batch-RINs:
              1-2007-9876-12345-00022-15-2-00002001-00003000
              1-2007-0987-12345-00022-10-2-00012001-00014000
 November 15: Marketer Moore takes ownership of 3000 gallons of denatured ethanol
       with 7500 assigned gallon-RINs in one batch-RIN:
              1-2007-1122-12345-00150-15-2-00001001-00008500
 December 15: Marketer Moore sells 1000 gallons of biodiesel to Blender Taylor with
       1500 gallon-RINs in two batch-RINs:
              1-2007-8765-12345-00022-10-2-00004055-00005054
              1 -2007-9876-12345-00022-15-2-00002001 -00002500
 December 31: Marketer Moore verifies that his end-of-quarter gallon-RINs do not
       exceed his end-of-quarter gallons adjusted for their Equivalence Value.

              14,000 gallon-RINs < 5000 gallons x Equivalence Value of 2.5
                                 + 1000 gallons x Equivalence Value of 1.5
	14,000 gallon-RINs < 14,000 gallons (adjusted)	

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 Example E-l	
 January 10: Marketer Anderson takes ownership of 5000 gallons of denatured ethanol
       with 5000 assigned gallon-RINs in one batch-RIN:
              1-2008-6543-12345-00088-10-2-00556701-00561700
 February 20: Marketer Anderson sells 2000 gallons of ethanol to Blender Jackson with
       5000 assigned  gallon-RINs:
              1-2008-6543-12345-00088-10-2-00556701-00561700
 March 31: Marketer Anderson verifies that his end-of-quarter gallon-RINs do not
       exceed his end-of-quarter gallons adjusted for their Equivalence Value.

              0 gallon-RINs ^ 3000 gallons x Equivalence Value of 2.5
	0 gallon-RINs < 7500 gallons (adjusted)	
                                       32

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