I will be making renewable gasoline from renewable crude. Section 80.1115(b)(6) of the regulations says I must use an Equivalence Value of 1.0 even though renewable gasoline clearly warrants a higher Equivalence Value. Can I submit a petition?

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Yes. See regulation Section 80.1115(c)(2). However, for renewable fuels other than renewable diesel which are made from renewable crudes, information on the energy content and/or renewable content may be difficult to obtain. This is why we designated the Equivalence Value for such fuels as 1.0, and specified that the applicable volumes must be measured according to the volume of renewable crude rather than the volume of the final product. In cases where information on the energy content and renewable content can be determined precisely, a different Equivalence Value may be warranted.

In addition, regulation Section 80.1126(d)(6) allows a party to petition EPA to use the volume of the renewable fuel produced as the basis for generating RINs rather than the volume of the renewable crude used to make that product.

Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (PDF) (55 pp, 221 K, EPA420-F-07-041a, August 2007, About PDF)