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

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The D code would identify cellulosic biomass ethanol batches as such. Since the<br />

Act requires that a minimum <strong>of</strong> 250 million gallons <strong>of</strong> cellulosic biomass ethanol be<br />

consumed starting in 2013, obligated parties will need to be able to distinguish RINs<br />

representing cellulosic biomass ethanol from RINs representing other types <strong>of</strong> renewable<br />

fuel. This requirement is discussed in more detail in Section III.A.<br />

The K code would be used to specify whether the RIN represents actual gallons <strong>of</strong><br />

renewable fuel, or instead represents extra-value RINs. Extra-value RINs arise only in<br />

cases where the Equivalence Value is greater than 1.0. Extra-value RINs are discussed in<br />

more detail in Section III.D.2.b below.<br />

The RIN also contains two values that together identify the total number <strong>of</strong><br />

gallons in a batch as well as uniquely identifying each gallon in that batch 29 . When RINs<br />

are first assigned to a batch <strong>of</strong> renewable fuel by its producer or importer, the volume<br />

start block for that batch will in general be 1 (i.e. SSSSSS will have a value <strong>of</strong> 000001).<br />

The volume block end is the total volume number <strong>of</strong> gallons in the batch (i.e. for a 10,000<br />

gallon batch, EEEEEE would have a value <strong>of</strong> 010000). Thus the single RIN assigned to<br />

the batch is in effect shorth<strong>and</strong> for all the unique RINs assigned to every individual<br />

gallon in the batch. We propose that the number <strong>of</strong> gallons in a batch be st<strong>and</strong>ardized to<br />

60 o F to avoid RIN assignment problems associated with volume swell due to<br />

temperature changes. We have assigned six digits to the volume block codes to allow<br />

batches up to a million gallons in size. We request comment on whether a fewer number<br />

<strong>of</strong> digits for the SSSSSS <strong>and</strong> EEEEEE codes would be sufficient.<br />

Since "RIN" can refer to either the number assigned to the batch or the number<br />

representing each gallon in that batch, we propose distinguishing between a batch-RIN<br />

<strong>and</strong> a gallon-RIN. A batch-RIN would be the multi-character code written on a product<br />

transfer document associated with a batch <strong>of</strong> renewable fuel. The batch-RIN would<br />

include SSSSSS <strong>and</strong> EEEEEE values identifying every (volume-st<strong>and</strong>ardized) gallon in<br />

the batch, each <strong>of</strong> which would be assigned its own gallon-RIN. A gallon-RIN would<br />

have identical SSSSSS <strong>and</strong> EEEEEE values identifying one gallon in a batch.<br />

Our approach to RINs permits the batch to be divided into smaller batches at any<br />

point in the distribution system while maintaining the assignment <strong>of</strong> unique RINs. For<br />

instance, if a 1000 gallon batch <strong>of</strong> renewable fuel is divided into two 500 gallon batches,<br />

the volume block start <strong>and</strong> block end values in the original batch-RIN would change to<br />

reflect the batch split. The batch-RIN for the first 500 gallon batch would have an<br />

SSSSSS value <strong>of</strong> 000001 <strong>and</strong> an EEEEEE value <strong>of</strong> 000500, while the second 500 gallon<br />

batch would have an SSSSSS value <strong>of</strong> 000501 <strong>and</strong> an EEEEEE value <strong>of</strong> 001000.<br />

Additional batch splits would be h<strong>and</strong>led similarly. More discussion <strong>of</strong> batch splits is<br />

provided in Section III.E.1.b.i.<br />

29 RINs represent actual gallons in a batch when the RIN is a st<strong>and</strong>ard-value RIN. Extra-value RINs<br />

represent additional gallons in cases where the Equivalence Value is greater than 1.0. See further<br />

discussion in Section III.D.2.b.<br />

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