It may be the case that some ethanol blended into gasoline at the beginning of the program will not have assigned RINs. However, the RVO is determined annually, not quarterly or monthly, and in general ethanol purchased after September 1, 2007 will have assigned RINs. Obligated parties can also acquire RINs in the first few months of 2008 that can be used to demonstrate compliance with their 2007 RVO.
Question and Answer was originally posted at http://www.epa.gov/otaq/renewablefuels/420f07041a.pdf
It appears we are creating an automatic non-compliance period for September, 2007. If I own ethanol on September 1, 2007, it will not have assigned RINs. As an obligated party, I will be blending this ethanol into gasoline at my terminal, but I won't be g
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