How to Prepared an Efficient
Producer Petition
Version 1*1
United States
Environmental Protection

How to Prepared an Efficient
Producer Petition
Version 1.1
Transportation and Climate Division
Office of Transportation and Air Quality
U.S. Environmental Protection Agency
United States
Environmental Protection
^1	Agency
October 2016

Table of Contents
1.	Introduction	2
2.	Section-by-Section Instructions	3
A.	Cover Sheet (No information claimed CBI)	3
B.	Feedstock (No information claimed CBI)	4
C.	Production Process	4
D.	Process Energy	5
E.	Coproducts	5
F.	Mass and Energy Balance Data	5
G.	Certification by the Responsible Corporate Officer (RCO)	6
H.	List of Attachments	7
Appendix A: Formatting for New Fuel Pathway Petitions	8
Appendix B: Petition Cover Sheet Template	9

1. Introduction
The EPA is providing detailed information on how to prepare a complete Efficient Producer (EP) petition
for a new fuel pathway under the Renewable Fuel Standard (RFS) program. Parties considering an EP
petition are strongly encouraged to start by reviewing the background information provided on the
EPA's website on whether they qualify for this expedited petition process.
This document provides details on the required information for EP petitions, including
recommendations on organization and formatting.1 Our objective is to help petitioners provide all of
the data that EPA needs to complete life cycle greenhouse gas (GHG) analyses of proposed new fuel
pathways, while also reducing extraneous information. EP petitions that do not meet the information
requirements specified in 40 CFR 80.1416, as explained and clarified in this document and other EPA
guidance, will be rejected as incomplete and no further action will be taken. In other words, the whole
petition will need to be resubmitted.
This document provides step-by-step instructions for preparing a complete EP petition. The
recommendations included in this document are based on EPA's experience implementing the petition
process since its creation in March 2010. As we continue to receive and evaluate more petitions, we
expect to update this document if we identify areas for improvement. We also welcome constructive
input from petitioners on how to improve this document. Stakeholders who wish to provide input can
do so by emailing the EPA Fuels Program Support Line at with "Petition
Process Input" as the subject line.
This document has been updated based on the release of Version 1.1 of the Efficient Producer
Greenhouse Gas Calculator and the accompanying instruction document, titled How to Use the Efficient
Producer Greenhouse Gas Calculator 1.1.
1 The information requested in this document is based on the information requirements for petitions outlined in
the RFS regulations at 40 CFR 80.1416(b).

2. Section-by-Section Instructions
As part of our efforts to streamline the petition review process, the EPA is asking petitioners to prepare
their application packages using the recommended organization and format provided in this document.
The following sections go through each part of the petition outline and provides guidance on what to
include in each section.2
For EPA to complete its evaluation of these petitions, it is necessary for the Agency to publicly disclose
certain information about requested pathways (e.g., the name of the company that submitted the
petition, the name and location of their biofuel production facility, the type(s) of feedstocks used, the
type of fuel produced and the type of production process technology). For this reason, EPA requests
that certain sections of the EP petition include no information claimed as confidential business
information (CBI). Below, these sections are marked as "(No information claimed CBI)."
We also recognize that petitioners may feel it is important to claim as CBI certain technical information.
Petitioners who wish to claim certain information as CBI should clearly mark all the information claimed
as CBI as precisely as possible. We ask petitioners to clearly mark each and every page that includes
information claimed as CBI. The header of all such pages should say "Contains information claimed as
CBI," and the header should also include an explanation of how such information is marked. For
example, the header could explain that information claimed CBI is included in brackets or highlighted
A. Cover Sheet [No information claimed CBI)
We ask that every petition include a one-page cover sheet. The cover sheet serves as a quick reference,
designed to help EPA staff efficiently and systematically process and review incoming petitions. An
example Cover Sheet is provided in Appendix B.
1.	Date Submitted
Enter the date that the petition is submitted to the EPA.
2.	Company Full Name
Enter the official name of the company submitting the petition. Enter only one company name.
3.	Name of Ethanol Production Facility
Give the name of the ethanol production facility associated with the petition.3 Please use a brief name
(we recommend no more than three words), as this will be the name used in the EPA Moderated
Transaction System (EMTS) and EPA's determination document. A company submitting petitions for
multiple facilities should make sure that each facility has a unique name. For example, facilities could be
named after the Company and the city where they are located, e.g., Acme Washington, Acme
Washington II, Acme Detroit. Enter only one facility per petition.
2	We ask petitioners to use the section headings specified below and in the table of contents (e.g., A. Cover Sheet,
B. Feedstock, C. Production Process, and so on). For more instructions on formatting see Appendix A.
3	In this document ethanol refers to undenatured ethanol.

4.	Location of Ethanol Production Facility
Specify the location (city, state, country) of the facility that will produce the ethanol associated with the
proposed pathway.
5.	Fuel Pathway Requested
Enter the fuel, feedstock and production process technology and RIN D-code for each pathway
requested. A single petition may involve more than one fuel pathway. For example, the petition may
request pathways for corn starch ethanol, grain sorghum ethanol qualifying for renewable fuel (D-code
6) RINs and grain sorghum ethanol qualifying for advanced biofuel (D-code 5) RINs. Add rows to the
table as necessary to include all of the fuel pathways requested. Below is an example of how to fill out
the table of requested fuel pathways.
Table 1: Example listing of requested fuel pathways
Fuel Type
RIN D-code
Corn starch
Dry mill process
Grain sorghum
Dry mill process
6. Primary Point of Contact
Provide the requested contact information (see Appendix B) for the primary point of contact (POC) for
the petition. Include only one POC per petition. EPA recommends that the POC should be affiliated with
the company listed in Section A(2). If the POC is not affiliated with the lead organization, at least one
appropriate official from the lead organization should be listed under the "Additional Contact Info"
section of the Petition Cover Sheet, and included in any subsequent meetings or calls related to the
petition. EPA will send all communications regarding a petition to the POC, and it is the POC's
responsibility to disseminate information to other parties associated with the petition. These
recommendations are intended to reduce duplicative communications between EPA and parties
associated with a petition.
B.	Feedstock [No information claimed CBI)
Provide a brief statement certifying the types of feedstocks that are used in the requested pathway(s).
For example, the statement can be as simple as the following: "I certify that the only feedstocks used to
produce ethanol at [insert facility name] are corn starch and grain sorghum."
C.	Production Process
Provide a brief statement certifying that the production process used to produce ethanol through the
requested pathway(s) is a dry mill ethanol production process. For more information about what

constitutes a dry mill ethanol production process, see Section ("Dry Milling Technology") of the
February 2010 Renewable Fuel Standard Program (RFS2) Regulatory Impact Analysis (EPA-420-R-10-
For example, the statement could say the following: "I certify that the requested pathways for ethanol
produced by [insert facility name] use a dry mill production process where corn starch and grain
sorghum feedstocks are ground into a coarse flour, also known as "meal"; the meal is cooked into a hot
slurry with the addition of enzymes to produce a mixture commonly known as "mash"; the mash is
fermented with the addition of yeast to produce ethanol, carbon dioxide and solids from the grain and
yeast, known as "fermented mash"; the fermented mash is distilled to produce a mixture of ethanol and
water, and a residue of non-fermentable solids, also known as "stillage"; the mixture of ethanol and
water is dehydrated to produce 200-proof ethanol; and the primary coproducts/byproducts are carbon
dioxide, distillers grains, solubles, syrup and vegetable oil."
D.	Process Energy
Provide a brief statement certifying that the dry mill process for the requested pathway uses one or a
combination of the following sources for all of its process energy: electricity from the grid, natural gas,
coal, biogas or biomass. If the requested pathway uses biogas for process energy, briefly describe the
sources of the gas. Note that to qualify for the EP petition process the biogas must be sourced from one
or a combination of the following sources: landfills, municipal wastewater treatment facility digesters,
agricultural digesters, separate municipal solid waste (MSW) digesters, or other waste digesters. See
the July 2014 RFS rule (79 FR 42128) for more information on qualifying sources of biogas.
If the requested pathway uses biomass for process energy, briefly describe the sources of the biomass.
Note that to qualify for the EP petition process, all biomass used as process energy must meet the RFS
regulatory definition for crop residue at  80.1401. See the July 2014 RFS rule for more information on
what EPA considers to be a crop residue for the RFS program.
E.	Coproducts
Provide a brief statement certifying that all of the distillers grains or distillers grains and solubles co-
product produced as a result of the requested pathways is intended for use as animal feed. This section
should also provide a brief description of the coproducts resulting from the requested pathways and
their intended uses. For example, explain whether the facility sells wet or modified distillers grains,
produces vegetable oil coproduct through fractionation or extraction, produces any additional co-
products, etc.
F.	Mass and Energy Balance Data
A mass and energy balance should be included for every new pathway requested. To provide the
required mass and energy balance data, petitioners should use the EP Lifecycle GHG Calculator
spreadsheet (the "GHG Calculator"), available for download on the Agency's EP petition process web

page.4 This spreadsheet tool is designed to automatically calculate lifecycle GHG emissions based on the
mass and energy balance data entered. Petitioners should fill out the GHG Calculator and attach it to
their EP petition. For detailed instructions on using the GHG Calculator, including the formulas and
emissions factors used in the calculations, see the How to Use the Efficient Lifecycle Greenhouse Gas
Calculator document available for download on EPA's EP web page.
The GHG Calculator submission should include average annual mass and energy balance data over the
past year and/or projected into the future. For EP petitions, data may be entered in the GHG Calculator
for a daily, monthly or annual basis. If mass and energy balance data provided is based on projected
process improvements, provide a brief explanation (less than one page) of the energy saving
technologies and other process improvements that will (or have been) undertaken to improve the
facility's future efficiency compared to its historical performance.
The data provided should demonstrate how the requested fuel pathway will meet the applicable
lifecycle GHG emissions reduction threshold (e.g., 20% GHG reduction for renewable fuel D-code 6 RINs,
50% GHG reduction for renewable fuel D-code 5 RINs) using the methodology described below. If you
submit an EP petition that does not demonstrate adequate GHG reductions EPA will return it as
Should the petition be approved, the average lifecycle GHG emissions for the ethanol produced at the
facility will need to be calculated and recorded over a 365 calendar day rolling average. The GHG
Calculator is designed to help perform these calculations as well.
G. Certification by the Responsible Corporate Officer (RCO)
EP petitions should include a signed statement by the RCO of the company (or facility) submitting the
petition,5 certifying that the information provided is accurate and the company understands and wishes
to comply with the steps and requirements in the EP petition process, as explained on the EPA's
website. The signed determination document responding to your petition will be addressed and mailed
5	For reference, a definition for responsible corporate officer is provided at 40 CFR 122.22:
(i)	A president, secretary, treasurer, or vice-president of the corporation in charge of a principal business function,
or any other person who performs similar policy- or decision-making functions for the corporation, or
(ii)	the manager of one or more manufacturing, production, or operating facilities, provided, the manager is
authorized to make management decisions which govern the operation of the regulated facility including having
the explicit or implicit duty of making major capital investment recommendations, and initiating and directing
other comprehensive measures to assure long term environmental compliance with environmental laws and
regulations; the manager can ensure that the necessary systems are established or actions taken to gather
complete and accurate information for permit application requirements; and where authority to sign documents
has been assigned or delegated to the manager in accordance with corporate procedures.

to the RCO listed in this section, based on the address provided in the GHG Calculator attached to your
petition (for details see the How to Use the Efficient Producer Greenhouse Gas Calculator document).6
Petitions should include the following statement, with information in brackets filled as appropriate,
followed by the RCO's signature, the RCO's printed name and the date:
As [RCO job title] of [company full name], I am providing to EPA information about a requested
new fuel pathway on behalf of [company full name], I have reviewed the information provided
above, and to the best of my knowledge it is accurate and complete. I have reviewed all of the
information related to the Efficient Producer petition process available on the EPA's website
and I certify that my organization wishes to utilize this process and understand the conditions
likely to be contained in any approval document, including those related to registration,
continuous monitoring and the recordkeeping that will be designed to ensure ongoing
compliance with the appropriate life cycle greenhouse gas reduction threshold requirements
associated with the approved pathway.
RCO Signature:
RCO Name (Printed:
H. List of Attachments
Provide a list of the attachments submitted with the petition, including a short name and brief
description (1-2 sentences) for each attachment.
6 The most recent version of the How to Use the Efficient Producer Lifecycle Greenhouse Gas Calculator is available

Appendix A: Formatting for New Fuel Pathway Petitions
Electronic file type: PDF or MS Word
Font and Section Headings:
	For the body of the document: Calibri, size 11, black color.
	First level section headings (e.g., B. Feedstock): Cambria, size 14, bold, no indent, capitalize
the first letter of each word, color = dark blue, insert page break before section heading.
	Second level section headings (e.g., 2. Information for New Feedstocks): Calibri, size
13, bold, capitalize the first letter of each word, color = blue.
	Third level section headings (e.g., vii. Alternative Uses): Calibri, size 11, indent by one tab,
capitalize the first letter of each word, color = blue.
	Fourth level section headings (e.g., d. Information for Livestock Feed): Calibri, size 11, italics,
indent by one tab, capitalize the first letter of each word, color = blue.
	Fifth level section headings (e.g., 1. Animal market share and feed ratios by region): Calibri,
size 11, normal font, indent by one tab, capitalize only the first letter of the first word, color =
dark blue.
Include a table of contents
Paper size: Standard 8.5 by 11-inch copier paper

Appendix B: Petition Cover Sheet Template
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Date Submitted: [MM/DD/YYYY]
[Company Full Name]
Abbreviated Company Name:
Location of Ethanol Production Facility: [City, State, Country]
Name of Ethanol Production Facility: [Abbreviated Company Name + Facility
Fuel Pathway Requested
Production Process
RIN D-code

Dry mill process

Point of Contact
Job Title:
Phone Number:
Alternate Phone Number:
Email address:
Additional Contact Info (if any):