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Who actually calculates the RVO? The refinery or EPA?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Each obligated party calculates the RVO itself, based on its annual gasoline volume. See regulation Sections 80.1152(a)(1)(v) and (vi). Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (PDF) (55 pp…
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We are a marketer of ethanol products. Sometimes personnel at ethanol plants make mistakes as to the number of gallons being loaded or produced. How do we "recall" erroneous RINs if the number of RINs exceeds the number of gallons we receive?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The parties (producers) selling ethanol to you have an obligation to transfer appropriate RINs to you. A producer who is also a marketer may assign up to 2.5 RINs per gallon of renewable fuel. A producer who is…
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We are an association. Many of our members are blenders who are small and who find the attest engagement (audit) requirement difficult and expensive to comply with. We would like to engage a CPA who would be able to perform the required review of our memb
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . We believe it may be appropriate for individual blenders to pay for CPA services through their association and recognize that this may result in a cost savings to them. Section 80.125(a), which is referenced by 80.1164, says: "Any…
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The following is a two-part question: a. We are a petroleum refiner and recognize that we are an obligated party under the regulation. We are considering importing ethanol that has not been denatured. We will hold title to the un-denatured ethanol. Title
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . A. Un-denatured ethanol is not a renewable fuel. See 80.1101(d)(3). Under the described scenario, the party to whom custody is transferred and who denatures the ethanol would be producer of the renewable fuel. B. Under the described scenario…
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Where a company is both an obligated party and an importer of renewable fuel, the company will generate RINs in its importer capacity and separate the RINs from the volume of imported fuel in its capacity as an obligated party. Is this activity considered
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No transaction report is required for internal company transfers as all RINs are owned at the corporate level. The company would submit a RIN generation report for the RINs it generated for the imported renewable fuel and a…
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When is a RIN generated for ethanol that is imported into the U.S.?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . 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…
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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
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . 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…
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I am an ethanol marketer and importer, and, although I am not certain, I may import gasoline before the end of the compliance year. Can I separate RINs from the ethanol that I purchase and import?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . In general, we believe that most RFS program participants will know at the beginning of the compliance year the nature of their business activities for the upcoming compliance period, and therefore will not need to worry about the…
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Which market indicators will cause EPA to change the RFS standard?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA will use information from the Energy Information Agency (EIA) that projects volumes of gasoline and renewable fuel in order to calculate the standard. Please refer to section 80.1105 of the regulation. Question and Answer was originally posted…
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What happens if, after submitting his annual compliance demonstration report, a refiner discovers that he exceeded the 20% cap on the use of previous-year RINs in meeting his RVO? Is he required to replace those RINs with new valid RINs at the old market
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Annual compliance demonstrations must include a showing that the RINs used to comply with the RVO include no more than 20% previous-year RINs. If it is determined that this showing was incorrect due to either a mathematical error…
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What's the difference between generating a RIN and assigning it?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . 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…
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If you have a spill, does the K code change to 2 for the spilled volume?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . No, the K code is not changed as the result of a spill. (Refer to section 80.1132 of the regulation regarding retirement of RINs due to a spill.) Question and Answer was originally posted at: Questions and Answers…
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A child’s consecutive visits to a particular building (such as a hospital) can technically qualify that building as a child-occupied facility, even if the visits were an isolated event. How long does such a building remain a child-occupied facility?
A child’s consecutive visits to a particular building (such as a hospital) can technically qualify that building as a child-occupied facility, even if the visits were an isolated or rare event. How long does such a building remain a child-occupied facility? Answer: A building, or portion of a building, is…
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Are renovations that disturb stucco subject to the RRP Rule? Does it matter whether the stucco has been painted?
Answer: The Lead Renovation, Repair, and Painting (RRP) Rule applies to work that disturbs painted surfaces. Therefore, renovations that disturb stucco are subject to the RRP Rule only if the stucco has been painted. Question Number: 23002-14025 Find a printable PDF copy of all frequent questions pertaining to lead .
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Does the Renovation, Repair, and Painting (RRP) Rule apply where no paint at all is present, such as in a 100 year old unfinished basement?
No. The RRP Rule applies to activities that result in the disturbance of painted surfaces. Where there is no paint to disturb, the RRP Rule does not apply. Question Number: 23002-15696 Find a printable PDF copy of all frequent questions pertaining to lead .
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