Marketers who buy and sell renewable fuel without blending it into gasoline or diesel cannot separate RINs from volumes, and thus cannot change the K code from 1 to 2. All conditions under which a party can separate RINs from volumes are set forth in regulation Section 80.1129(b). However, a marketer can indeed decide not to transfer a particular RIN with a volume of renewable fuel so long as the end-ofquarter check described in regulation Section 80.1128(a)(5) is fulfilled.
Question and Answer was originally posted at http://www.epa.gov/otaq/renewablefuels/420f07041a.pdf
Does regulation Section 80.1128(a)(4) allow a marketer to change the K code from 1 to 2 and then not transfer the RIN with the renewable fuel as long as he sells the RINs to anyone by the end of the quarter?
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