Guidance for RFS 2012 Annual

            Compliance Reporting
&EPA
United States
Environmental Protection
Agency

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         Guidance for RFS 2012  Annual
               Compliance Reporting
                        Compliance Division
                  Office of Transportation and Air Quality
                  U.S. Environmental Protection Agency
United States
Environmental Protection
Agency
EPA-420-B-12-066
November 2012

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 Guidance for RFS 2012 Annual Compliance Reporting

This guidance document is intended to assist obligated parties and renewable fuel exporters in
reporting their RFS2 Renewable Volume Obligations (RVOs) reporting for the 2012 compliance
year.  The reports for 2012 are due February 28, 2013. In addition to this guidance document,
EPA has posted RVO Q&As that can be found on the RFS web site at:
http://www.epa.gov/otaq/fuels/renewablefuels/compliancehelp/rfs2-aq.htmtf7.

Any obligated party, as described in §80.1406, that produced or imported gasoline or MVNRLM
diesel fuel for use in the contiguous 48 states plus Hawaii (Alaska if they opt-in) during a given
compliance period must submit an RFS2 Annual Compliance Report pursuant to §80.1451(a).

Any exporter of renewable fuels, as described in §80.1430, that exported a volume of renewable
fuel from the contiguous 48 states plus Hawaii (Alaska if they opt-in) during a given compliance
period must submit an RFS2 Annual Compliance Report pursuant to  §80.1451(a).

Parties that have more than one business activity that generate multiple Renewable Volume
Obligations (RVOs), must report the information separately (i.e. imports, exports, and refining
obligations must be met separately). Further, prior to retiring RFS2 RINs for compliance,
gasoline and diesel refiners are required to indicate the compliance level that they choose to
report based on (aggregate or refinery by refinery) in the OTAQReg:  Fuels Programs
Registration interface on Central Data Exchange (CDX). Note: The compliance level only needs
to be indicated in OTAQReg once unless the company plans to change their compliance level.
However, if the obligated party carries a deficit from one year to the next, then the party must
maintain the same approach to aggregation in the next calendar year per §80.1427(b)(l)(iv).

The guidance document will briefly discuss features that have been implemented in EMTS to
assist obligated parties and renewable fuel exporters with their RFS2  annual compliance
requirements. These features will aid users in completing their RFS0303 Annual Compliance
Report, which is required pursuant to §80.1451(a). For more information on all EMTS features,
please visit the EMTS  documents webpage at:
http://www.epa.gov/otaq/fuels/renewablefuels/emtshtml/emtsdocuments.htm

Regulated parties may use this document to aid in achieving compliance with the RFS2 program
regulations.  However, this document does not in any way alter the requirements of those
regulations.  This 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.

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Table of Contents
1.0 General Information for Obligated Parties	3
  1.1 What information do I have to submit for 2012 Annual Compliance?	3
  1.2 What RINs can be used to satisfy each Renewable Volume Obligation?            3
  1.3 What is the last day that I can obtain RINs for compliance?                      4
  1.4 EMTS Features	6
2.0 Obligated Parties: Gasoline or Diesel Refiners	7
  2.1 Refiners: Selecting  Compliance Level in CDX	7
  2.2 Refiners: RFS0303  Guidance                                                 8
  2.3 Refiners: Deficit Carryovers	9
3.0 Obligated Parties: Gasoline or Diesel Importers	10
  3.1   Importers: RFS0303 Guidance                                             10
  3.2 Importers: Deficit Carryovers	11
4.0   Renewable Fuel Exporters                                                   12
  4.1 Exporters: RFS0303 Guidance                                                12
  4.2 Exporters: Deficit Carryovers	13
5.0   Purchasing Cellulosic Biofuel Waiver Credits	14
  5.1 Pay.gov Electronic Payments	14
      5.1.1 Adding Pay.gov Application to an Existing CDX Account	14
      5.1.2 Accessing the Cellulosic Biofuel Waiver Credit Program Application	18
  5.2 Electronic Payments via Fedwire	23
  5.3 Mail Payment	23

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1.0 General Information for Obligated Parties

All obligated parties are required to submit the RFS0303: RFS2 Annual Compliance Report.
The RFS0303 report is used to demonstrate compliance with the Renewable Volume Obligations
that obligated parties and renewable fuel exporters acquired based on their compliance year
activities.

The following information is general information for all obligated parties and exporters.  Specific
information based on the business activities of an obligated party or exporter can be found in
sections 2 through 4.

1.1 What information do  I have to submit for 2012 Annual Compliance?

Obligated parties and renewable fuel exporters are required to submit all information listed in
§80.145 l(a).  All of the required RFS2 RIN information will be entered and submitted in the
RFS0303 report.

The RFS2 RIN information submitted on the RFS0303 report satisfies all of the requirements in
80.145l(a). Therefore, a partial EMTS Transaction History report showing all RINs retired for
compliance purposes does not need to be submitted on February 28 but will be submitted on
Quarter 1 reports instead.

1.2 What RINs can be used to satisfy each Renewable Volume Obligation?

In 2012, only RFS2 RINs (transacted in EMTS) may be used for compliance purposes. For 2012
compliance, unused 2010 RFS1 RINs are not eligible to be used for compliance purposes.

Different Types  of RINs:
Under RFS2, certain types of RINs can be used to fulfill various obligations.  Pursuant to 40
CFR 80.1427(a)(2)-(4), the following types of RINs may be used to satisfy the specific RVOs:

RINs Generated Under RFS2

    •   RINs with a D code of 3 or 7 are valid for compliance with the cellulosic biofuel RVO.
       Note:  If a RIN with a D code of 7 is used to meet the biomass-based diesel RVO, then it
       may not  be used to satisfy the cellulosic biofuel RVO.
    •   RINs with a D code of 4 or 7 are valid for compliance with the biomass-based diesel
       RVO.  Note: If a RIN with a D code of 7 is used to meet the cellulosic biofuel RVO, then
       it may not be used to satisfy the biomass-based diesel RVO.
    •   RINs with a D code of 3, 4, 5, or 7 are valid for compliance with the advanced biofuel
       RVO.
    •   RINs with a D code of 3, 4, 5, 6, or 7 are  valid for compliance with the renewable fuel
       RVO.
Renewable Volume Obligation Nesting:

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RVOs are "nested," meaning that certain types of RINs can be used to satisfy multiple RVOs.
For example, a RIN with a D code of 4 may be used toward satisfying a biomass-based diesel
RVO, an advanced biofuel RVO, and renewable fuel RVO for the same compliance year.
However, a RIN with a D code of 5 or 6 may not be used to meet a biomass-based diesel RVO.
Table 1 - Which RIN D codes can satisfy each Renewable Volume Obligation (RVO)
pursuant to 40 CFR 80.1427(a)(2)-(4)?
DCode
3
4
5
6
7
Cellulosic
Biofuel RVO
X



X*
Biomass-Based
Diesel RVO

X


X*
Advanced
Biofuel RVO
X
X
X

X
Renewable Fuel
RVO
X
X
X
X
X
Note: X* indicates a RIN with a D code of 7 may be used to meet either the Cellulosic Biofuel
RVO or the Biomass-Based Diesel RVO, but not both RVOs pursuant to 40 CFR 80.1427(3)(ii).
Additional Notes:
    1) When filling out the RFS0303 report, parties must carry the entire number of RINs used
      for compliance purposes throughout the nested standards regardless of showing an excess
      of RINs for another RVO category, (e.g. In a given compliance year, the number of
      cellulosic biofuel and biomass-based diesel may cover the advanced biofuel RVO in
      excess.  The number of RINs retired should not be reduced to equal the advanced biofuel
      RVO, but instead should show a retirement in excess for the advanced biofuel RVO row.)

             For example:
          •  An obligated party uses 400 D3 2012 RFS2 RINs for compliance, then 400 must
             appear in field 16 for the rows with "CB", "AF", and "RF" in field 9.
          •  An obligated party uses 110,000 D4 2011 RFS2 RINs for compliance, then
             110,000 must appear in field 17 for the rows with "BD", "AF", and "RF" in field
             9.

    2) RINs can only be used in one compliance year

             For example:
          •  An obligated party cannot use a D5 RIN to fulfill the advanced biofuel RVO 2011
             and then use the same RIN to fulfill the renewable fuel RVO in 2012.
1.3 What is the last day that I can obtain RINs for compliance?

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RFS2 RINs used to meet the 2012 obligation may be traded until February 28, 2013. For the
2012 compliance year, the RFS0303: RFS2 Annual Compliance Report must be submitted on
February 28, 2013. The RFS0300: Annual Compliance Report was for compliance years 2007
through 2009, the RFS0301: RFS2 2010 Annual Compliance Report was for compliance year
2010, and the RFS0302: RFS2 2011 Annual Compliance Report was for compliance year 2011.

Additional RFS2 EMTS RIN Notes:
    1.  In order to  retire RFS2 RINs for compliance by the deadline, all transactions must be
       completed  and processed in EMTS prior to the deadline. Although EMTS can accept and
       process certain transactions rather quickly, RIN retirements may take longer to process
       when multiple RIN batches are involved.  Therefore, parties should try to complete their
       RIN retirements by February 21, 2013.  If EMTS is unable to process the transactions by
       February 28, then those RINs will be unavailable for retirement for that compliance year.

    2.  As discussed above, RIN retirements may take longer to process when multiple REST
       batches are involved. Due to a longer processing time, a session in the EMTS User
       Interface may timeout prior to the processing completion. Therefore, EPA suggests that
       parties who intend  to retire a large quantity of RINs for compliance use an XML file.
       XML files  should be submitted at least one week prior to the compliance deadline (e.g.
       February 21).  Obligated parties using the web user interface should retire no more than
       one million RINs at a time to avoid system delays.
   3.  RINs may not be retired for compliance purposes after February 28, 2013 for the 2012
       compliance year.

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1.4  EMTS Features
Compliance Data User Interface in EMTS
                                                                               Home | Contact Us \ Help | Logout
                                                                Logged in as: LucyPelt for RAP Inc. GEN Biodiesel (4671)
   View Aggregate RINs Retired for Obligation
                                                                              » Transaction Bin
    The following grid displays the number of RINs your organization has retired for obligation.
                                                           Your organization has 0
                                                           un-submitted
                                                           transactions in the
                                                           transaction bin,
                                                                              View Transaction Bin
                                                                               Organizations
                                                                               Quick Search
        Fuel (D-Code)
   Advanced Biofuel (D=5)
   Biomass-Based Diesel (D=4)
   Renewable Fuel (D=6)
   Export options: CSV | Excel | PDF
2010
2010
2010
                                    Compliance Year  Yl  Compliance Level
2D10             Aggregated Importer
2010             Aggregated Importer
2010             Refinery by Refinery
                                         Valley Medico Plant 12 (46711)
34000
71500
39000
The Compliance Data user interface page in EMTS is a listing of all RINs retired for compliance,
broken out by:
    •   RIN Type (D code)
    •   RIN Year
    •   Compliance Level (AGREF, AGIMP, EXPRT, or refinery-by-refinery)
    •   RIN Quantity
Obligated parties should use this page to accurately reflect the correct RIN quantities that have
been retired for compliance on the Annual Compliance Report.  This page will assist parties to
complete fields 15 through 24 of the RFS0303: 2012 Annual Compliance Report.
This interface can be found under the Reports Tab on the horizontal toolbar in EMTS.

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2.0 Obligated Parties: Gasoline or Diesel Refiners

Refiners of gasoline or diesel may comply in the aggregate or on a refinery-by-refinery basis.
Prior to the retirement of RFS2 RINs in EMTS, refiners must update their registration via the
OTAQReg: Fuels Programs Registration application to indicate how they plan to comply.

Note: The compliance level only needs to be indicated in OTAQReg once unless the company
plans to change their compliance level. However, if the obligated party carries a deficit from one
year to the next, then the party must maintain the same approach to aggregation in the next
calendar year per §80.1427(b)(l)(iv).

2.1 Refiners: Selecting Compliance Level in CDX

Pursuant to 80.1406(c)(l), an obligated party may comply with its annual compliance
requirements for all of its refineries in aggregate, or for each refinery individually. However, if
the obligated party carries a deficit from one year to the next, then the party must maintain the
same approach to aggregation in the next calendar year per §80.1427(b)(l)(iv).

Note: The compliance level only needs to be indicated in OTAQReg once unless the company
plans to change their compliance level. The compliance level must be submitted and activated
by EPA prior to the retirement of RINs for compliance.

In order to select the compliance level, a CDX user will login to CDX and:
    1.  Select the OTAQReg: Fuels Programs Registration link.
    2.  On the OTAQ Registration Program Home page, select your company by clicking the
       Company Name.
    3.  Select the EDIT button in the top right corner of the page.
    4.  Scroll down to the bottom of the page and select the compliance level.
  - Refiner Compliance Level
   * Pursuant to 80.1 406!c)(l), an obligated party may comply with its annual compliance requirements for all of its refineries in
   the aggregate, or for each refinery individually. However, if the obligated party carries a deficit from one year to the next, then
   the party must maintain the same approach to aggregation in the next calendar year. Please indicate the compliance level
   below:
   '-i' Aggregation of Refineries

   O N;A (Biodiesel Produ

   O Refinery-by-refinery
) N;A (Biodiesel Producers Only)
       Once the compliance level has been selected, if no other updates need to be made in the
       registration, click Review at the top corner of the page.
       Review the information.  The user will be unable to edit any information on this page.  If
       the information looks correct, click Submit at the bottom of the page.
       The user must save and print out the PDF forms that are generated on the Company
       Information: Print and Sign page. Once the forms are printed, click Continue.

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       Note:  The PDF registration must be printed and signed by the responsible corporate
       officer (RCO) that EPA currently has on file for the company. These forms must be sent
       to EPA by either:

               TTOA/r.,                            Commercial Delivery:
               US Mail:                     TT „ _   .       ^ , _  ^   .J  .
  TTO  _  .         ,_     .    .              U.S. Environmental Protection Agency
  U.S. Environmental Protection Agency            _   , „       „   .  .  ..   °   J
   17   i n       n  •  4.  *•   f£A^T\             Fuels Programs Registration
   Fuels Programs Registration (6406J)              _     ^^^ ™~-,„-,  ,™oo
     IIAAT,      i   -A      \ni7-               Room 647C, 202-343-9038
     1200 Pennsylvania Avenue, NW                   , 0, „ T '    ^ , „,,
         „,  ,.      T^™,,™                       1310 L Street, NW
         Washington, DC 20460                                  '
                0                                  Washington, DC 20005


   8.  You will be taken back to the OTAQ Registration Home page where you should be able
       to see  a pending company update request.

2.2 Refiners: RFS0303 Guidance (also available in the RFS0303 report instructions)

The RFS0303 reporting instructions can be found on the Renewable Fuel Standards Reporting
Forms web page at http://www.epa.gov/otaq/fuels/reporting/rfs.htm.

In [Field No. 8] of the RFS0303 report, the refiner must enter either AGREF (aggregate) or the 5
digit facility ID (refinery-by-refinery). Regardless, the refiner will have at least four rows, one
for each RVO (renewable fuel, advanced biofuel, biomass-based diesel and cellulosic biofuel.)

Note: If complying refinery-by-refinery, the obligated party should have one row for each RVO
at each refinery (e.g. 2 refineries will have 8 rows, 3  refineries will have 12 rows, etc.).

   Fields that must contain "NA" in the RFS0303: RFS2 Annual Compliance Report
   •   For a row with field 9 as CB, "NA" must be entered in field 17,18,19,20,21,22,23,24
   •   For a row with field 9 as BD, "NA" must be entered in field
       15,16,19,20,21,22,25,26,27,28
   •   For a row with field 9 as AB, "NA" must be entered in field 21,22,26,27,28
   •   For a row with field 9 as RF, "NA" must be entered in field 26,27,28

   Prior-year RIN limits
   •   For a row with field 9 as CB, the amount of prior year 2011 RINs that may be used for
       compliance must satisfy the following formula:
                          [No. 15] + [No. 23] < 0.20 x [No. 13]
   •   For a row with field 9 as BD, the amount of prior year 2011 RINs that may be used for
       compliance must satisfy the following formulas:
                          [No. 17] + [No. 23] < 0.20 x [No. 13]
   •   For a row with field 9 as AB, the amount of prior year 2011 RINs that may be used for
       compliance must satisfy the following formulas:
                 [No. 15] + [No. 17] + [No. 19] + [No. 23] < 0.20 x [No. 13]

   •   For a row with field 9 as RF, the amount of prior year 2011 RINs that may be used for
       compliance must satisfy the following formulas:

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[No. 15] + [No. 17] + [No. 19] + [No. 21] + [No. 23] < 0.20 x [No. 13]

2.3 Refiners: Deficit Carryovers

An obligated party who fails to meet its obligation in a given year may carryover a deficit into
the following year pursuant to 40 CFR 80.1427(b) given that they meet the following
requirements:
   •   A deficit has not been carried over from the previous year for that specific RVO; and
   •   The party meets all RVOs of the deficit category in the following year.

A deficit is calculated according to the following formula:

                       D;= RVO;- [(ERINNUM)i+ (ERINNUM)i-l]

Where:

       D;= The deficit, in gallons, generated in calendar year i that must be carried over to year
       i+1 if allowed pursuant to paragraph (b)(l) of this section.

       RVO;= The Renewable Volume Obligation for the obligated party or renewable fuel
       exporter for calendar year i, in gallons.

       (ERINNUM)i= Sum of all acquired gallon-RINs that were generated in year i and are
       being applied towards the RVO;, in gallons.

       (ERINNUM)i-l= Sum of all acquired gallon-RINs that were generated in year i-1 and are
       being applied towards the RVO;, in gallons.

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3.0 Obligated Parties: Gasoline or Diesel Importers

Importers of gasoline or diesel must comply in aggregate.

In [Field No. 8] of the RFS0303 report, the importer must enter AGIMP and will have four rows,
one for each RVO.

3.1 Importers: RFS0303 Guidance

The RFS0303 reporting instructions can be found on the Renewable Fuel Standards Reporting
Forms web page at http://www.epa.gov/otaq/fuels/reporting/rfs.htm.

   Fields that must contain "NA" in the RFS0303: RFS2 Annual Compliance Report
   •  For a row with field 9 as CB, "NA" must be entered in field 17,18,19,20,21,22,23,24
   •  For a row with field 9 as BD, "NA" must be entered in field
       15,16,19,20,21,22,25,26,27,28
   •  For a row with field 9 as AB, "NA" must be entered in field 21,22,26,27,28
   •  For a row with field 9 as RF, "NA" must be entered in field 26,27,28

   Prior-year RIN limits
   •  For a row with field 9 as CB, the amount of prior year 2011 RINs that may be used for
      compliance must satisfy the following formula:
                          [No. 15]  + [No. 23] < 0.20 x [No. 13]
   •  For a row with field 9 as BD, the amount of prior year 2011 RINs that may be used for
      compliance must satisfy the following formulas:
                          [No. 17]  + [No. 23] < 0.20 x [No. 13]
   •  For a row with field 9 as AB, the amount of prior year 2011 RINs that may be used for
      compliance must satisfy the following formulas:
                [No.  15] + [No. 17]  + [No. 19] + [No. 23] < 0.20 x [No. 13]

   •  For a row with field 9 as RF, the amount of prior year 2011 RINs that may be used for
      compliance must satisfy the following formulas:
[No. 15] + [No. 17] + [No. 19] + [No. 21] + [No. 23]  < 0.20 x [No. 13]
                                                                                  10

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3.2 Importers: Deficit Carryovers

An obligated party who fails to meet its obligation in a given year may carryover a deficit into
the following year pursuant to 40 CFR 80.1427(b) given that they meet the following
requirements:
   •   A deficit has not been carried over from the previous year for that specific RVO; and
   •   The party meets all RVOs of the deficit category in the following year;.

A deficit is calculated according to the following formula:

                       D;= RVO;- [(ERINNUM)i+ (ERINNUM)i-l]

Where:

       D;= The deficit, in gallons, generated in calendar year i that must be carried over to year
       i+1 if allowed pursuant to paragraph (b)(l) of this section.

       RVO;= The Renewable Volume Obligation for the obligated party  or renewable fuel
       exporter for calendar year i, in gallons.

       (ERINNUM)i= Sum of all acquired gallon-RINs that were generated in year i and are
       being applied towards the RVO;, in gallons.

       (ERINNUM)i-l= Sum of all acquired gallon-RINs that were generated in year i-1 and are
       being applied towards the RVO;, in gallons.
                                                                                     11

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4.0 Renewable Fuel Exporters

Renewable fuel exporters must comply in aggregate.

In [Field No. 8] of the RFS0303 report, the exporter must enter EXPRT and will have between
one and four rows based on the export activity.

Note: Renewable fuel  exporters that have an RVO other than renewable fuel incur nested
obligations (e.g. for an export of biodiesel, an exporter will have a Biomass-Based Diesel RVO,
an Advanced Biofuel RVO, and a Renewable Fuel RVO).  Table 2 describes which volumes of
renewable fuel need to be included when an exporter calculates their RVO(s), pursuant to
§80.1407.

       Table 2 - This table provides examples of which volumes of a renewable fuel export
           incur specific Renewable Volume Obligations (RVO) pursuant to §80.1430.
Renewable Fuel
Export
Biodiesel
Non-Ester
Renewable Diesel
Cellulosic Biofuel
Cellulosic Diesel
Advanced Biofuel
Renewable Fuel
Cellulosic
Biofuel RVO
No
No
Yes
Biomass-Based
Diesel RVO
Yes
Yes
No
Either Cellulosic Biofuel or
Biomass-Based Diesel (only 1)
No
No
No
No
Advanced
Biofuel RVO
Yes
Yes
Yes
Yes
Yes
No
Renewable
Fuel RVO
Yes
Yes
Yes
Yes
Yes
Yes
4.1 Exporters: RFS0303 Guidance

The RFS0303 reporting instructions can be found on the Renewable Fuel Standards Reporting
Forms web page at http://www.epa.gov/otaq/fuels/reporting/rfs.htm.

   Fields that must contain "NA" in the RFS0303: RFS2 Annual Compliance Report
   •  For a row with field 9 as CB, "NA" must be entered in field
       17,18,19,20,21,22,23,24,26,27,28
   •  For a row with field 9 as BD, "NA" must be entered in field
       15,16,19,20,21,22,25,26,27,28
   •  For a row with field 9 as AB, "NA" must be entered in field 21,22,26,27,28
   •  For a row with field 9 as RF, "NA" must be entered in field 26,27,28

   Prior-year RIN limits
   •  For a row with field 9 as CB, the amount of prior year 2011  RINs that may be used for
      compliance must satisfy the following formula:
                          [No.  15] + [No. 23] < 0.20 x [No. 13]
                                                                                  12

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   •   For a row with field 9 as BD, the amount of prior year 2011 RINs that may be used for
       compliance must satisfy the following formulas:
                          [No. 17] + [No. 23] < 0.20 x [No. 13]
   •   For a row with field 9 as AB, the amount of prior year 2011 RINs that may be used for
       compliance must satisfy the following formulas:
                 [No. 15] + [No. 17] + [No. 19] + [No. 23] < 0.20 x [No. 13]

   •   For a row with field 9 as RF, the amount of prior year 2011 RINs that may be used for
       compliance must satisfy the following formulas:
[No. 15] + [No. 17] + [No. 19] + [No. 21] + [No. 23]  < 0.20 x [No. 13]

4.2 Exporters: Deficit Carryovers

An obligated party who fails to meet its obligation in a given year may carryover a deficit into
the following year pursuant to 40 CFR 80.1427(b) given that they meet the following
requirements:
   •   A deficit has not been carried over from the previous year for that specific RVO; and
   •   The party meets all RVOs of the deficit category in the following year.

A deficit is calculated according to the following formula:

                       D;= RVO;- [(ERINNUM)i+ (ERINNUM)i-l]

Where:

       D;= The deficit, in gallons, generated in calendar year i that must be carried over to year
       i+1 if allowed pursuant to paragraph (b)(l) of this section.

       RVO;= The Renewable Volume Obligation for the obligated party or renewable fuel
       exporter for calendar year i, in gallons.

       (ERINNUM)i= Sum of all acquired gallon-RINs that were generated in year i and are
       being applied towards the RVO;, in gallons.

       (ERINNUM)i-l= Sum of all acquired gallon-RINs that were generated in year i-1 and are
       being applied towards the RVO;, in gallons.
                                                                                    13

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5.0 Purchasing Cellulosic Biofuel Waiver Credits

Any obligated party, as described in §80.1406, that produces or imports Gasoline or MVNRLM
Diesel fuel for use in the contiguous 48 states plus Hawaii (Alaska if they opt-in) during a given
compliance period, must submit an RFS2 Annual Compliance Report under §80.1451(a).

Pursuant to §80.1456, if EPA reduces the applicable volume of cellulosic biofuel pursuant to
section 21 l(o)(7)(D)(i) of the Clean Air Act (42 U.S.C. 7545(o)(7)(D)(i)) for any given
compliance year, then EPA will provide cellulosic biofuel waiver credits for purchase for that
compliance year. This excludes biodiesel producers registered as diesel refiners and does not
apply to renewable fuel exporters.

EPA has three methods for obligated parties to purchase EPA Cellulosic Biofuel Waiver Credits
(Only one may be used):
    1.  Pay.gov electronic payment (credit card, debit card,  or eCheck);
    2.  Fedwire payment (bank wire transfer); or
    3.  Mail Payment (paper check).
5.1 Pay.gov Electronic Payments


The OTAQ Cellulosic Biofuel Wavier Credits application is hosted by the Central Data
Exchange (CDX). CDX is the system that EPA has provided to all programs to standardize and
centralize the reporting functions and data submissions that are required of the various EPA
regulated communities. In order to access Cellulosic Biofuel Waiver Credits, users must first be
registered users of CDX.
5.1.1  Adding Pay.gov application to an existing CDX account:
In order to access Pay.gov, the user must add the application to their CDX account. Please add
the Pay.gov application by following these steps:
   •   Login to CDX (http://cdx.epa.gov)
   •   You will be at the MyCDX page.  Please select the "Edit Current Account Profiles" link:
                                                                                     14

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                       Central  Data  Exchange- MyCDX
 Welcome.
 CDX Registration Status:  Active
                        Last Login:
                        Registered Since:
                        Re certification Date:
                        February 22, 2011
                        May 7, 2009
                        May 7, 2009
                           You have 3 new messages in your Inbox
 Change System
 Password
Edit Personal
Information
j^dit Current  ^N
vAccount Profiles/
 Available Account Profiles:
Add New
Employer Profile
   On the Edit Organization Profiles, select the "Add New Program" link:

                       Program Status
                         Edit Organization Contact Information

                         OTAQEMTS
                         OTAQREG
                            New Program
                        Add additional programs for Compass
•  On the Add Program page, find the "Cellulosic Biofuel Waiver Credits Pay.gov
   Application (OTAQWaiverCredits) and click "Add":
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         Assessment Cleanup and Redevelopment Exchange System (ACRES):  Q
                                     Environmental Appeals Board (EAB):  O
                                 Audit Policy Self-Disclosure (eDisclosure):  O
                         Facility Registry System - Update Service (FRS-US):  O
               Great Lakes Environmental Database Query System (GLENDA):  O
               Exchange Network Grant Semi-Annual Reporting Forms (IEPB}:  O
                                      Lead-Based Paint Program (LEAD}:  O
                        LT2: LT2, Stage 2, and IDSE Plan/Report Entry (LT2):  O
             National Environmental Methods Index Contaminants (NEMI-CBR):  O
                                     Ozone Depleting Substances (ODS):  O
      C e 11 u I o s i c B i ofu e I Wa ive r C re d its P a y. g o v Ap p I i cati o n (OTAQ Wa i ve rC re d its;:<^~
                                          Radionuclide NESHAPs (RAD):  O
                                           Radiation Network (RADNET):  O
                              Storm water Notice of Intent (eNOI) (SWENOI}:  O
                       Toxi c Re I e a s e I nve nto ry M a d e E a sy We b (TRIM Ewe b):  O
                                      TRI State Data Exchange  (TRISDX):  O
                                                        TSCAtJSCA):  O
                     Toxic Substance Control Act - HaSD Form (TSCA-HASD}:  O
                                Compliance Information Systems (VERIFY}:  O
         Request Manufacturer Code for OTAQ Compliance (VERIFY MFR REG):  O
                               Wate r C o nta m i n a nt I nf o rm ati o n To o I (WC IT):  O
•   On the Add Role page, all fields are completed with the exception of the "ID" field. Per
    the instructions, please enter "N/A" and click "Add":
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                                           Add Program ID

         Use the TAB key to move from field to field. * = REQUIRED FIELD
                                 Role:
A SUBMITTER v
                       Program ID Type:
                     Submission Method:
WEBFORM
                                                          lease enter N/'A.
    •  You will then receive the following message:
 MvCDX > Registration
  Congratulations! You have successfully completed the online portion of CDX registration You should receive an e-mail confirmation shortly confirming receipt of your information-
Note:  EPA must activate the addition ofPay.gov to your CDX profile. Until EPA has activated
this, you will not be able to see the Pay.gov application.

In order to activate the Pay.gov application, users must submit a letter, on company letterhead
requesting the activation of the Pay.gov application:

To Whom It May Concern:
I, [Insert RCO name], [Insert RCO Title], of [Insert Company Name and EPA ID] establish
[User Name] of [User Company] as a delegate for the purpose of submitting the following
reports for me to the US Environmental Protection Agency via the Central Data Exchange
(CDX):

OTAQWaiverCredits: Cellulosic Biofuel Waiver Credits Pay.gov Application—Company
Submitter Role—Pay.gov portal: Pay.gov is used to purchase cellulosic biofuel waiver credits to
be applied to a company's RVO. In order to use this application, the user must know the amount
of cellulosic biofuel waiver credits that the company needs.  Additionally, a company may not
purchase more credits than their company needs; nor may a company transfer  credits to another
party.
RCO Wet Ink Signature
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5.1.2 Accessing the Cellulosic Biofuel Waiver Credit Program Application
In order to access the Cellulosic Biofuel Waiver Credit Program Application, the
"OTAQWaiverCredits: Cellulosic Biofuel Waiver Credits Pay.gov Application" must be active
in the user profile. Once it is active, it will show up on the MyCDX homepage. Click on the
"OTAQWaiverCredits: Cellulosic Biofuel Waiver Credits Pay.gov Application" link to continue.
       The Cellulosic Biofuel Waiver Credit Program Home page looks like this:
    Cellulosic Biofuel Waiver Credits
                    Cellulosic Biofuel  Waiver Credit Home
                      About Cellulosic Biofuel Waiver Credits
                          40CFR 80.1405 f

                         56(b) Use of cellulos
    •   Once on the homepage, click on "Purchase Credits" link to the left of the page.

    •   The "Purchase Information" page is where you will provide your payment information:
    Cellulosic Biofuel Waiver Credits
                    Purchase Credits
                       Purchase Information
                      Price per credit for 2010: $1. 56

                      Company:        MRRInc[3244]    "

                      Compliance Level:

                      Facility ID:

                      Number of Credits:
Aggregate Refiner v
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•  The following information must be provided on the Purchase Credits page:
       o  Company Name (selected from the drop down menu);
       o  Compliance Level;
       o  Facility ID (only required if complying on a refinery by refinery basis); and
       o  Number of Credits to be purchased.
•  Once all the information has been entered on the Purchase Credits page, click the
   "Calculate Total" button.
•  This will direct you to the Review Purchase Information page:
 Cellulosic Biofuel Waiver Credits
                 Review Purchase Information
                   Purchase Information
                   Vou are purchasing 300 credits at a price of $ 1.56 per credit for a total of $468.00.

                   Note: Your order will not be complete until you submit payment information to Pay.gov
•  Confirm the following information on the Purchase Information page
       o  Amount of credits being purchased;
       o  Per-credit price; and
       o  Total purchasing price.
•  If all the information looks correct click the "Continue to Pay.gov" button.
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The Payment Information must be entered in order to continue with the purchase:
               United States Environmental Protection Agencv
 Cellulosic Biofuel  Waiver  Credits
 System Message
      The system has populated the Payment Dote with the next available payment date.
   Online Payment
   Step 1: Enter Payment Information
   Pay Via Bank Account (ACH) About ACH Debit
   Required fields are indicated with a red asterisk *
                                                              Return to your originating application
                        Account Holder Name:
                            Payment Amount: $312 DO
                               Account Type: |
                             Routing Number:
                             Account Number: |
                      Confirm Account Number:
                              Check Number: \
                                                     vl*
                                          Routing Number

                                       •:'o 3E.qUE.7Bl1':
                                                                   Account Number
                                                                         I
                                                                                     Check Number
                                                                         7E. 7 IRQ"'  I 3
                         Payment Date: 02/10/2011
                     Ntimbei of Credits: 200
                Total Purchase (in USD): 312.0
                       Company Name: MRR Inc
                          Company ID: 3244
Facility ID (only if complying on a Refiner by
                         Refiner basis):
  Select the"Continue with ACH Pajxcmit" button to ei
                                   Continue with ACH PaymentJJ) Cancel
                                                     tajfae^next step in the ACH Debit Payment Process.
  Note: Please avoid navigating the site using your browser's Back Button - this may lead to incomplete data being transmitted
  and pages being loaded incorrectly. Please use the links provided whenever possible.
        Once all the information is added, click the "Continue with ACH Payment" button to
        continue.
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   •   The Authorize Payment page contains the payment summary.  Users may opt to enter in
       an email address to receive a confirmation receipt if they choose.
x>EPA
              United States Environmental Protection Agency
Cellulosic Biofuel  Waiver  Credits
  Online Payment
  Step 2: Authorize Payment
  Payment Summary   Edit this information
                                                          Return to your originating application
                                                                            Payment Date: 02/02/2011
                                                                         Number of Credits: 200
                                                                    Total Purchase (in USD):312.0
                                                                           Company  Name: MRR Inc
                                                                              Company ID: 3244
                                                    Facility ID {only if complying on a Refiner by
                                                                             Refiner  basis):
  Email Confirmation Receipt
  To have a confirmation sent to you upon completion of this transaction, provide an email address and confirmation below.
                Email Address:
Account Holder Name: Test
    Payment Amount: $312.00
       Account Type: Personal Checking
     Routing Number: 042000424
    Account Number: 1111
      Clieck Number: 1111
         Confirm Email Address:
                          CC:
                                                                            multiple email addresses with a
  Authorization and Disclosure
  Required fields are indicated witb a red asterisk^
  I agree to the authorization and disclosure language
   Authorisation and  Disclosure—Consumers  and Businesses
                                                                                               -
   The debit, transaction(s)  to which you  are agreeing are  handled on behalf  o±  Federal
   agencies by "Pay.gov,"  which consists  of services offered by the U.S. Treasury
   Department's Financial  Management Service.  As used in this document, "we" or "us"
   refers to the Financial Management Service  and its agents and contractors operating
   Pay.gov. "You" refers to the end-user  reading this document and agreeing  to  it prior
   to  engaging in a  debit  transaction.

   I.  Consumers

   A.  Authorization

   You acknowledge that  you have read and understand the consumer disclosure language and
   authorise the Federal Reserve financial institution of  Cleveland to debit the named
   financial institution account. This  authorization is to remain in full force and
   effect until we have  received notification of its termination in such time and in such
   manner as to afford Pay.gov a reasonable opportunity to act on it, or unless otherwise
   terminated for any  reason by Pay.gov.

   B.  Disclosure
                                                                                               -
  View Authorization and Disclosure in a separate window.
    Press the "Submit Payment" Button only once._Pjpssmn th.p juitton more than once could result in multiple transactions.
                                       Submit Payment 3 Cancel
Note: Please avoid navigating the site using your browser's Back Button - this may lead to incomplete data being transmitted
and pages being loaded incorrectly. Please use the links provided whenever possible.
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    •  If all the information is correct, the user must read accept the Authorization and
       Disclosure statement by clicking on the check box. Then the user may click "Submit
       Payment".

    •  Once the submission has been accepted, the Credit Purchase History Detail page will
       be displayed. At the top of this page, it will indicate that the submission was a  success:
         Cellulosic Biofuel Waiver Credits
                        Credit Purchase History Detail
                         • Your payment has been successfully received

                         - Purchase Information
                         Transaction ID:

                         Status:

                         Purchase Date:

                         User ID:

                         User Name:
EPAOTAQBIOFUEL00002 01

Success

02/01/2011 11:46 AM

JENNIFERPAINE

Jennifer L Paine
                         Company:

                         Compliance Level:

                         Number of Credits

                         Price per credit:

                         Total Purchase:

                         Year
MRR Inc |3244|

 gregate Refiner

200

$1.56

1312.00

2010
Congratulations! You have successfully submitted your payment to purchase cellulosic biofuel
waiver credits.
If you have any general or technical questions related to the Central Data Exchange (CDX) you
may contact any of the following:

  • Telephone - Person-to-person telephone support is available from the CDX Help Desk 8:00
    am - 6:00 pm EST. Call our toll-free line at 888-890-1995.
  • Email - Send e-mail to Technical Support at helpdesk@epacdx.net with "Technical Support"
    in the Subject line.
  • Fax- Assistance requests are accepted 24 hours a day at 703-227-4199. Support personnel
    will respond to faxed requests Monday through Friday from 8:00 am to 6:00 pm EST.
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5.2 Electronic Payments via Fedwire

Be sure to include your Company Name, Company ID and reference "EPA Cellulosic Biofuel
Waiver Credits" on the funds transfer.

Receiving Financial Institution = TREAS NYC
Receiving FI ABA (routing #) = 021030004
Beneficiary Account = 68011233
Beneficiary Name = EPA

On the RFS0303 Report, [Field No. 26] = Fedwire

5.3 Mail Payment

Parties must submit the RFS2 Cellulosic Biofuel Waiver Credit Form along with their paper
checks. This form can be found on the RFS Reporting Forms webpage
http ://www. epa.gov/otaq/fuel s/reporting/rfs .htm.

In addition to the form mentioned above, paper checks must have the following information:

   •   Pay to the order of: U. S. EPA
   •   Memo: RFS2 - CB

Address for check payments:
US Environmental Protection Agency
Las Vegas Finance Center
PO Box 979087
St. Louis, MO 63197-9000

On the RFS0303 Report, [Field No. 26] = Mail

Additional Notes:
   •   Renewable Fuel Exporters and other non-obligated parties may not purchase EPA
       cellulosic biofuel waiver credits
   •   Pursuant to 80.1456(b)(2), EPA cellulosic biofuel waiver credits are nonrefundable.
   •   Pursuant to 80.1456(b)(3), EPA cellulosic biofuel waiver credits are nontransferable.
   •   Pursuant to 80.1456(b)(4), EPA cellulosic biofuel waiver credits may only be used for an
       obligated party's current year cellulosic biofuel RVO and not towards any prior year
       deficit cellulosic biofuel volume obligations.
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