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

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Another case in which a RIN may not be assigned to a batch <strong>of</strong> renewable fuel would<br />

be if the renewable fuel was consumed within the confines <strong>of</strong> the production facility where it<br />

was made. RINs under today's proposal would be assigned to renewable fuel when it leaves<br />

the production facility. So long as renewable fuel remained at the production facility, it<br />

would not need to be assigned a RIN.<br />

A third case in which some renewable fuel would not be assigned a RIN would occur<br />

for small volume producers. We are proposing that renewable fuel producers who produce<br />

less than 10,000 gallons in a year would not be required to generate RINs or assign them to<br />

batches. If they chose to register as a renewable fuel producer under the RFS program,<br />

however, they would be subject to all the regulatory provisions that apply to all producers,<br />

including the requirement to assign RINs to batches. We request comment on the 10,000<br />

gallon threshold.<br />

A fourth case in which some renewable fuel would not be assigned a RIN could occur<br />

when a gasoline or diesel blending component is only partially derived from a renewable<br />

source. In such cases the Equivalence Value associated with the renewable fuel would be<br />

less than 1.0, indicating that it is produced by combining a renewable fuel with a nonrenewable<br />

fossil fuel. For instance, ethyl tertiary butyl ether (ETBE) is made from<br />

combining ethanol with isobutylene. The ethanol is generally from corn, <strong>and</strong> the isobutylene<br />

is generally from petroleum. Equivalence Values are discussed in Section III.B.4. In this<br />

situation only a fraction <strong>of</strong> the gallons <strong>of</strong> renewable fuel produced would be assigned a RIN<br />

in proportion to its Equivalence Value, with the remaining gallons not being assigned a RIN.<br />

Finally, a renewable fuel whose energy content is less than that <strong>of</strong> ethanol might also<br />

be assigned an Equivalence Value less than 1.0, <strong>and</strong> as a result fewer gallon-RINs would be<br />

assigned to a batch than physical gallons in that batch. For example, methanol made from<br />

biogenic methane (biogas) for use in a methanol vehicle would have an energy content less<br />

than that for ethanol. Although methanol is currently used as a fuel in only very small<br />

quantities, if it was produced from renewable feedstocks it would have an Equivalence Value<br />

less than 1.0.<br />

If a renewable fuel has a Equivalence Value less than 1.0, then gallon-RINs could<br />

only be assigned to a portion <strong>of</strong> the batch. The number <strong>of</strong> gallons within a batch that could<br />

be assigned a RIN would be calculated from the following formula:<br />

where:<br />

Va = EV x Vs<br />

Va = Volume <strong>of</strong> the batch that is assigned a RIN, in gallons (rounded to the nearest<br />

whole gallon)<br />

EV = Equivalence Value for the renewable fuel in question (≤ 1.0)<br />

= Total volume <strong>of</strong> the batch st<strong>and</strong>ardized to 60 o F, in gallons<br />

Vs<br />

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