Do grandfathered facilities have an additional 6 months to submit their engineering reviews to EPA?
Yes. In the preamble to the final RFS2 regulations at 75 Fed. Regs. 14709 (March 26, 2010), EPA stated that, in an effort to reduce demand on engineering resources in the interim between promulgation of the rule and July 1, 2010, the agency would allow grandfathered facilities an additional six months from the July 1, 2010 deadline to submit their engineering review (to be submitted no later than December 31, 2010).
The regulations did not include this flexibility. EPA intends to propose changes in a direct final rule in the near future to amend the regulations to allow grandfathered facilities an additional six months from the July 1, 2010 deadline to submit their engineering review.