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

temperature. For instance, under extreme changes in temperature, the volume of a batch
of ethanol can change by 5 percent or more. For this reason we are proposing that all
batch volumes be corrected to represent a standard condition of 60 o F prior to the
assignment of a RIN. For ethanol 32 , we propose that the correction be done as follows 33 :
where
Vs,e = Va,e x (-0.0006301 x T + 1.0378)
Vs,e = Standard volume of ethanol at 60 o F, in gallons
Va,e
T
= Actual volume of ethanol, in gallons
= Actual temperature of the batch, in o F
Since batches of ethanol are generally sold using standard volumes rather than actual
volumes, this approach to assigning RINs to batches would be consistent with current
practices and would maintain the one-to-one correspondence between the volume block
in the batch-RIN and the standardized volume of the batch. We propose a similar
approach to biodiesel, where the volume correction can be calculated using the following
equation 34 :
where
Vs,b = Va,b x (-0.0008008 x T + 1.0480)
Vs,b = Standard volume of biodiesel at 60 o F, in gallons
Va,b
T
= Actual volume of biodiesel, in gallons
= Actual temperature of the batch, in o F
The RIN would have to be assigned to a batch no later than the point in time when
the batch physically leaves the production or importing facility. Although ownership of
the batch may be retained by the producer or importer, the RIN would nevertheless be
required to be transferred along with the batch as it leaves the originating facility. This
requirement would ensure that RINs could be verified against production or importing
facility records and against mandated reports to the Energy Information Administration
(EIA). It would also centralize the process of assigning RINs to batches.
The means through which RINs would be transferred with batches would in some
respects be left to the discretion of the renewable fuel producer or importer. The primary
requirement would be that the RIN be included on a product transfer document (PTD).
The PTD can be included in any form of standard documentation that is already
associated with or used to identify title to the batch. The batch documentation must be of
the sort that uniquely identifies the batch and is generally transferred from one party to
32 An appropriate temperature correction for other renewable fuels should likewise be used.
33 Derived from "Fuel Ethanol Technical Information," Archer Daniels Midland Company, v1.2, 2003
34 Derived from R.E. Tate et al, "The densities of three biodiesel fuels at temperatures up to 300 oC", Fuel
85 (2006) 1004 - 1009, Table 1 for soy methyl ester
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