Regulation of Fuels and Fuel Additives: Renewable Fuel Standard ...

Our proposed RIN-based program would address all these concerns automatically by
shifting the focus of accounting to the point of production rather than blending. As a result
we believe that a blender-based alternative approach described above is inferior to our
proposed program. We request comment on a RIN-based system for uniquely identifying,
measuring, and tracking batches of renewable fuel for compliance purposes.
2. Generating RINs And Assigning Them To Batches
a. Form Of Renewable Identification Numbers
Each RIN would be generated by the producer or importer of the renewable fuel and
would uniquely identify not only a specific batch, but also every gallon in that batch. The
RIN would consist of a 34-character code having the following form:
Where
RIN: YYYYCCCCFFFFFBBBBBRRDKSSSSSSEEEEEE
YYYY = Calendar year of production or import
CCCC = Company ID
FFFFF = Facility ID
BBBBB = Serial batch number
RR = Code identifying the Equivalence Value
D = Code identifying cellulosic biomass ethanol or waste-derived ethanol
K = Code identifying extra-value RINs
SSSSSS = Start of volume block
EEEEEE = End of volume block
Some examples of RINs are given in Section III.E.1.b.
The company and facility IDs would be assigned by the EPA as part of the
registration process as described in Section IV.B. The serial batch number would be
chosen by the producer and would generally be a sequential value starting with 000001 at
the beginning of each year. We have chosen five digits for the serial batch number to
allow for facilities that produce up to a hundred thousand batches per year. However, we
request comment on whether four digits would be sufficient.
The RR, D, and K codes would together describe the nature of the renewable fuel
and the RINs that were generated to represent it. The RR code would simply represent
the Equivalence Value for the renewable fuel, multiplied by 10 to eliminate the decimal
place inherent in Equivalence Values. Equivalence Values form the basis for the total
number of RINs that can be generated for a given volume of renewable fuel, and are
described in Section III.B.4.
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