Three year engineering review updates for renewable fuel producers
This page will assist renewable fuel producers in completing their three-year engineering review (ER) update obligations under EPA’s Renewable Fuel Standard (RFS).
- 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- A Company Update Request must be submitted in CDX OTAQREG to update any registration information that has become outdated.
|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:
If any registration information has become outdated, the renewable fuel producer must generate a Company Request (CR) for a Company Update in CDX OTAQREG.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:
The professional engineer should then submit the engineering review (ER) report via one of the following methods:
Additional information for professional engineers: