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How will the volume of corn ethanol produced above the grandfathering threshold be treated?
How does a foreign grandfathered renewable fuel production facility processing a mixture of feedstocks with different D codes or no D codes classify its production into D code categories so RINs can be generated when the product is imported into the U.S.?
How long will the grandfathering provision be effective? Once a grandfathered producer registers and completes their engineering review, will their baseline volume ever need to meet the 20% GHG reduction requirement?
Table 1 in 80.1426 does not include a coal fired ethanol plant. If a coal fired plant can be demonstrated as "grandfathered-in," can we assume the ethanol produced will have a D code of 6?
If a facility is grandfathered, is it also exempt from the requirement that feedstocks must be renewable biomass?
Are Canadian facilities included in the grandfathering provision? Does the grandfathering provision extend to facilities that commenced production up to December 31, 2009?
Do grandfathered facilities have an additional 6 months to submit their engineering reviews to EPA?
What is meant by "grandfathered" fuel?