A. Un-denatured ethanol is not a renewable fuel. See 80.1101(d)(3). Under the described scenario, the party to whom custody is transferred and who denatures the ethanol would be producer of the renewable fuel.
B. Under the described scenario, RINs would be generated by the party who denatures the ethanol and produces the renewable fuel. See 80.1126(d). If the petroleum refiner wishes to generate RINs, then the petroleum refiner would have to keep title to the ethanol throughout the described transaction.
Question and Answer was originally posted at http://www.epa.gov/otaq/renewablefuels/420f07041a.pdf
The following is a two-part question: a. We are a petroleum refiner and recognize that we are an obligated party under the regulation. We are considering importing ethanol that has not been denatured. We will hold title to the un-denatured ethanol. Title
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