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

In addition to the requirements for attest engagements under §§80.125 through 80.133,
and other applicable attest engagement provisions, the following annual attest
engagement procedures are required under this subpart.
(a) The following attest procedures shall be completed for any obligated party as
stated in §80.1106(b) or exporter of renewable fuel that is subject to the
renewable fuel standard under §80.1105:
(1) Annual summary report.
(i) Obtain and read a copy of the annual summary report required under
§80.1152(a)(1) which contains information regarding:
(A) The obligated party’s volume of finished gasoline, reformulated gasoline
blendstock for oxygenate blending (RBOB), and conventional gasoline
blendstock that becomes finished conventional gasoline upon the addition of
oxygenate (CBOB) produced or imported during the reporting year;
(B) Renewable volume obligation (RVO); and
(C) RINs used for compliance.
(ii) Obtain documentation of any volumes of renewable fuel used in gasoline during
the reporting year; compute and report as a finding the volumes of renewable fuel
represented in these documents.
(iii) Agree the volumes of gasoline reported to EPA in the report required under
§80.1152(a)(1) with the volumes, excluding any renewable fuel volumes,
contained in the inventory reconciliation analysis under §80.133.
(iii) Verify that the production volume information in the obligated party’s annual
summary report required under §80.1152(a)(1) agrees with the volume
information, excluding any renewable fuel volumes, contained in the inventory
reconciliation analysis under §80.133.
(iv) Compute and report as a finding the obligated party’s RVO, and any deficit RVO
carried over from the previous year or carried into the subsequent year, and verify
that the values agree with the values reported to EPA.
(v) Obtain documentation for all RINs used for compliance during the year being
reviewed; compute and report as a finding the RIN numbers and year of
generation of RINs represented in these documents; and agree with the report to
EPA.
(2) RIN transaction report.
(i) Obtain and read a copy of the RIN transaction report required under
§80.1152(a)(2) which contains information regarding RIN trading transactions.
(ii) Obtain contracts or other documents for all RIN transactions with another party
during the year being reviewed; compute and report as a finding the transaction
types, transaction dates and RINs traded; and agree with the report to EPA.
(3) RIN activity report.
(i) Obtain and read a copy of the RIN activity report required under §80.1152(a)(3)
which contains information regarding RIN activity for the compliance year.
(ii) Obtain documentation of all RINs acquired, used for compliance (including
current-year RINs used and previous-year RINs used) transferred, sold, and
expired during the year being reviewed; compute and report as a finding the total
RINs acquired, used for compliance, transferred, sold, and expired as represented
in these documents; and agree with the report to EPA.
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