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Three year engineering review updates for renewable fuel producers

Important Announcement

Please see the following guidance for revised instructions:

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This page will assist renewable fuel producers in completing their three-year engineering review (ER) update obligations under EPA’s Renewable Fuel Standard (RFS).

General Instructions

  • Producers should use this page in conjunction with the regulations, not in lieu of reading the regulations.
  • For a full description of the registration requirements, see:
  • Renewable fuel producers must submit a new engineering review by January 31st every three years for each renewable fuel production facility. For example, a renewable fuel production facility activated in CDX OTAQReg in 2010 would be due for an engineering review update on 1/31/2013, 1/31/2016, and every three years after that.
  • A Company Update Request must be submitted in CDX OTAQREG to update any registration information that has become outdated.

Step-by-step Instructions

  Steps for completing the three year engineering review update Additional Information
1 The renewable fuel producer must assemble all materials required under §80.1450(b)(1).

Read the following engineering review template for an outline of the requirements under §80.1450(b)(1):
2 The renewable fuel producer must obtain an engineering review conducted by an independent third-party professional engineer per §80.1450(b)(2).  
3 The professional engineer must verify and explain how they evaluated the accuracy of all materials assembled by the producer per §80.1450(b)(1).

Read the following guidance on items the engineer must verify:
4 The professional engineer must include a detailed review of the renewable fuel producer’s VRIN calculations per §80.1450(b)(3)(iii).

The VRIN calculation review is not required for foreign renewable fuel producers that do not generate RINs.

Read the following guidance on VRIN calculations:
5

If any registration information has become outdated, the renewable fuel producer must generate a Company Request (CR) for a Company Update in CDX OTAQREG.

If the RCO has e-signature capabilities, he/she should e-sign the CR Company Update to complete this step in the process.

If the RCO does NOT have e-signature capabilities, print the paperwork and then mail the signed CR Company Update paperwork to:

For more information about CR Company Updates, read Section 7 "Update a Company" in this document:

For more information on RCO e-signatures, see:
6

The professional engineer should then submit the engineering review (ER) report via one of the following methods:

  • If the independent third-party professional engineer is associated with the renewable fuel producer in CDX OTAQREG with the “Independent Third Party Engineer” role, the engineer may electronically submit the engineering review and materials required under §80.1450(b)(1) to EPA. If associated, the engineer has two options for electronic submission:
    • Upload the engineering review and materials required under §80.1450(b)(1) in CDX DCFUEL, making sure to select the “Third Party Engineering Review” certification statement checkbox when prompted. 
    • Fill out and submit the engineering review webform available within CDX OTAQREG.
  • If the independent third-party professional engineer does NOT have e-signature capabilities, he/she should mail the ER report to:

Additional information for professional engineers:

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