No, as long as the blender actually blends the renewable fuel into gasoline or diesel. In that case, the blender would be required to separate the assigned RINs from the blended renewable fuel, and could then transfer the RINs to any party without simultaneously transferring a volume of renewable fuel. See regulation Sections 80.1128(a)(3) and 80.1129(b)(2).
Question and Answer was originally posted at http://www.epa.gov/otaq/renewablefuels/420f07041a.pdf
The final rule on page 23909 (Federal Register, volume 72) states that any non-obligated party that takes ownership of the renewable fuel with RINs will be required to transfer those RINs with a volume of renewable fuel. Does this refer to oxygenate blend
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