The EPA requests RIN Integrity Reports as a condition of resolving violations by the terms in the Interim Enforcement Respolicy (IERP), “The report shall describe the methodology or system that the company has implemented or adopted at the time of the report to ensure that RINs it uses to satisfy its [Renewable Volume Obligation, or RVO] are valid.”
Obligated parties may have implemented different methods or systems to ensure valid RINs are used to satisfy their RVOs. EPA, therefore, will defer to the party preparing the RIN Integrity Report to determine the precise content of the report. At a minimum, the report should include:
1. copies of all written procedures and protocols that the company has implemented to ensure valid RINs are used to satisfy their RVOs
2. a narrative description of how these procedures or protocols have been implemented, and
3. a narrative description of any other methods or systems that the company has implemented that are not set forth in the written procedures or protocols.