EPA is proposing - Petroleum Equipment Institute

engines, and the producer generally does not know how it will be used, we cannot requirethat producers or importers of these fuels generate RINs for all the volumes they produceas we do with other renewable fuels.Our proposal to allow electricity, natural gas, and propane to generate RINs undercertain conditions is consistent with our treatment of neat renewable fuels under RFS1and EISA's requirement that all transportation fuels be included in RFS2. With specificregard to renewable electricity, Section 206 of EISA requires the EPA to conduct a studyof the feasibility of issuing credits under the RFS2 program for renewable electricity usedby electric vehicles. Once completed, this study will provide additional informationregarding the means by which renewable electricity is able to generate RINs under theRFS2 program.As an alternative to allowing producers and importers of electricity, natural gas,and propane to generate RINs if they can demonstrate that their product is a renewablefuel and it is used as transportation fuel, we could allow or require parties who supplythese fuels to centrally-fueled fleets to generate the RINs even if they are not theproducer of the fuel. This approach would treat the supplier of the fuel to the fleet as theproducer or importer who then generates RINs, as they are the party who in effectchanges the fuel from a fuel that can be used in a variety of ways and ensures that it is infact used as transportation fuel. This alternative approach might enable a larger volumeof electricity, natural gas, and propane that is made from renewable biomass and which isactually used in vehicles or engines to be included in our proposed fuels program as RINgenerating,since in many cases a supplier could document the use of these fuels invehicles or engines, while a producer could not. In addition, in this case the supplier isthe party who causes the fuel to transition from general fuel supply to fuel designated foruse in motor vehicles or nonroad applications—in that sense, the supplier is more like aproducer or importer than the upstream producer or importer. However, if we were toallow the supplier of renewable electricity, natural gas, or propane to generate RINs insuch cases, it may also be appropriate to require suppliers of fossil-based electricity,natural gas, or propane to determine a Renewable Volume Obligation (RVO) thatincludes these fuels used as transportation fuel. See Section III.F.3 for further discussion.We request comment on this alternative approach for generating RINs for renewableelectricity, natural gas and propane.The term “Renewable Biomass” as defined in EISA, means:1. Planted crops and crop residue,2. Planted trees and tree residues,3. Animal waste material and byproducts,4. Slash and pre-commercial thinnings (from non-federal forestlands),5. Biomass cleared from the vicinity of buildings and other areas to reducethe risk of wildfire,6. Algae, and7. Separated yard waste or food waste.47