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.
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).
Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (PDF) (55 pp, 221 K, EPA420-F-07-041a, August 2007, About PDF)