Guidance for Updating Engineering 

Reviews and Other Facility Registration 

Information 
Compliance Division

Office of Transportation and Air Quality

U.S. Environmental Protection Agency

Guidance for Updating Engineering 

Reviews and Other Facility Registration 

Information 

EPA-420-B-13-043

September 2013
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GUIDANCE FOR UPDATING ENGINEERING REVIEWS AND OTHER FACILITY 

REGISTRATION INFORMATION

Who must submit updated Registration Information and an updated Engineering Review 

by January 31, 2014? 

For all producers of renewable fuel and foreign ethanol producers registered in calendar 

year 2011, the updated registration information and independent third-party engineering 

review shall be submitted to EPA by January 31, 2014. 

What are the Requirements for the 2014 Updated Registration Information and 

Engineering Review?

40 CFR 80.1450(d)(3) requires all producers of renewable fuel and foreign ethanol producers to 

update registration information and submit an updated independent third-party engineering 

review. All information previously submitted in support of registration should be reviewed and 

brought up to date, using the process described below. An updated third party engineering report 

with supporting documentation must be electronically signed and submitted by a qualified 

independent third party engineer; an addendum is not sufficient. EPA recommends that the 

engineer uses the Engineering Review Template when writing the engineering review. The PE

should upload the signed and stamped page with the engineering review.

In addition to conducting the engineering review and providing the written report and 

verification required by 80.1450(b)(2), the updated independent third-party engineering review 

must, pursuant to 80.1450(d)(3)(iii), include a detailed review of the renewable fuel producer's 

calculations used to determine the volume of RINs (VRIN) for a representative sample of batches 

of each type of renewable fuel produced since the 2011 registration. 80.1450(d)(3)(iii) refers to 

VRIN calculations as required by 80.1426(f). Representative samples must be selected in 

accordance with 40 CFR 80.127. 

EPA intends to initiate a process to deactivate the RFS2 Part 80 registration of any 2011 cohort 

RFS2 producer facility that has not submitted an updated registration and engineering review by 

January 31, 2014. 

 

How does the renewable fuel producer review and update their registration information in 

EPA’s Central Data Exchange (CDX)? 

1. As a user associated with your company in CDX OTAQReg with the Company 

Editor role, log-in to CDX, click “Fuels Programs Registration” to access 

OTAQReg, click your company’s name under “Company Information”, and 

select the “Edit” button in the upper right portion of the webpage. 

2. At this point you can make any necessary edits to your Company Details. Be sure 

to then select the “Facility Details” tab and click the name of any listed facilities 

to review your facility registration information.

3. After making any necessary edits to your facility information, click the “Save 

Facility” button. Once all facilities that require an engineering review update 

have been reviewed in CDX OTAQReg, click the “Review” button. This will 
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generate a view of your existing registration, select “continue” at the bottom of 

the screen. 

4. You can then click the “Sign Electronically” or “Print, Sign, and Mail button” to 

generate your request. Be sure to then save a copy of your request, have the RCO 

sign this document, and send all pages to EPA to the appropriate address listed at 

the bottom of this document. 

o Note, if your RCO is registered for RCO e-signature capability, your 

request will be listed with the status “Awaiting RCO Electronic Signature” 

under “Pending Requests” on your CDX OTAQReg. In this case, the 

RCO should log-in to CDX OTAQReg to electronically submit the request 

to EPA. 

What documents must the renewable fuel producers supply to the third-party professional 

engineer? 

1. Records that support the facility's baseline volume, permitted capacity, and/or 

actual peak capacity as listed in CDX OTAQReg (most recent applicable air 

permits and/or copies of documents demonstrating each facility's actual peak 

capacity)

o For permitted capacity, a current permit that lists the registered/requested 

capacity volume 

o For actual peak capacity, current production records 

2. Current process heat fuel supply plan pursuant to 80.1450(b)(1)(iv) (including 

name and address of supplier(s)) 

3. Revised version of any applicable separation plan submitted pursuant to 

80.1426(f)(5) 

o yard waste

o municipal solid waste

o separated food waste 

 Must be submitted by any company that has selected any of the 

following as a feedstock for an approved pathway (80.1426 Table 

1) in CDX:

• non-cellulosic portions of separated food waste, 

• cellulosic components of separated food waste, 

• biogenic waste oils/fats/greases 

 In order to expedite the review we suggest that 

companies submit details of the feedstock(s) they 

are using if a separated food waste plan is not 

applicable. Companies should supply enough 

information to demonstrate that the feedstock 

qualifies as renewable biomass.

What must the third-party independent professional engineer submit to EPA and how does 

the engineer submit this information? 

1. The third-party independent professional engineer who completes the engineering 

review and on-site facility visit must first associate with the renewable fuel 

producer in CDX OTAQReg with the “Independent Third-Party Engineer” role.
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2. This role will allow the professional engineer to review the company’s 

registration information and also electronically submit the engineering review and 

all required supporting documentation 

3. See the New User with an EPA Registered Company guide for assistance with 

associating with a company in CDX OTAQReg

o When first creating a CDX account and adding the OTAQReg program 

service, be sure to register under your third-party organization 

 After this initial CDX registration, you will be able to enter the 

OTAQReg program service and initiate a Company Association 

Request for the registered renewable fuel producer you are 

reviewing.

4. In order to review a company’s CDX OTAQReg registration information after 

associating with the company, the professional engineer will need to log-in to 

CDX, click on “Fuels Programs Registration”, click on the company’s name 

under “Company Information”, click the “View Request” button (if visible), click 

the “Facility Details” tab, and click the name of the appropriate facility. 

5. The third-party independent professional engineer must electronically submit a 

complete engineering review with all required information and all required 

supporting documentation as described in 80.1450(b)(2). EPA recommends that 

the engineer use the Engineering Review Template when writing the engineering 

review.

o The professional engineer will need to log-in to CDX and click the “Add 

Program Service” button to add the OTAQDCFUEL program service if 

they do not already have this Program Service listed in CDX.

o Once the professional engineer has the OTAQDCFUEL program service, 

they will be able to click the “OTAQ DC Fuel Application” link on their 

MyCDX home page. They will be prompted to confirm the company’s 

RCO information and identify as a professional engineer submitting an 

engineering review. 

o The professional engineer will then need to click the “Original” radio 

button and attach the engineering review along with the supporting 

documentation and click the “Encrypt and Sign” button. 

 If the engineering review and supporting documentation consist of 

multiple files, please zip these files into a single zip file using an 

appropriate program (e.g., Winzip). 

 Note: If, after the initial submission of the engineering review and 

supporting documentation, the professional engineer needs to 

submit additional and/or amended materials, the professional 

engineer should select the “Resubmission” radio button and 

provide a comment in OTAQDCFUEL indicating the date of the 

original submission and the reason for resubmission. 

o The professional engineer must then select the “Third Party Engineering 

Review” checkbox, click the accept button, and follow the e-signature 

instructions to submit the engineering review to EPA. 

6. In order to ensure that the information is properly updated we suggest that the 

third party engineer conduct the on-site visit no more than 120 days prior to 
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January 31, 2013. If an on-site visit was completed outside this timeframe, contact 

EPA’s Fuels Program Support by email at support@epamts-support.com. 

 

What Other Information is Helpful to Know?

• Copying and pasting entire sections/paragraphs of the regulations into the engineering 

review is unnecessary.

• The engineering review requires detailed explanations for several items; generally yes/no 

answers are not sufficient and could lead to delays in EPA’s review process.

• Submit all required supporting documentation (permits, plans, process). Simply stating 

that a document was reviewed (ie: Engineer reviewed air permit) is not sufficient. 

• The third-party independent professional engineer who conducts the on-site review and 

writes the engineering review must also sign and submit the engineering review 

electronically in CDX OTAQDCFUEL. Engineering review updates submitted by other 

individuals, or submitted by mail, will not be accepted. 

Where Can I Get More Information?

EPA’s Engineering Review Template:

http://www.epa.gov/otaq/fuels/renewablefuels/documents/420b13044.docx

Complete engineering review guidance:

http://www.epa.gov/otaq/fuels/renewablefuels/compliancehelp/420b10024.pdf

Registration requirements under § 80.1450

Contact Fuels Program Support: support@epamts-support.com

How do I send my CDX OTAQReg-generated Company Update Request to EPA? 

The RCO-signed Company Update Request may be sent to one of the following 

addresses: 

US Mail:

U.S. Environmental Protection Agency 

Fuels Programs Registration (6406J) 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Commercial Delivery:

U.S. Environmental Protection Agency

Fuels Programs Registration 

Room 647C; 202-343-9038 

1310 L Street, NW 

Washington, DC 20005

 

Regulated parties may use these guidelines to aid in achieving compliance with the RFS2 

program regulations. However, these guidelines do not in any way alter the requirements of those 

regulations. While the guidance provided in these guidelines reflect the Agency’s general plans 

for implementation of the regulations at this time, some of the guidance may change as 

additional information becomes available, or as the Agency further considers certain issues. 

These compliance guidelines do not establish or change legal rights or obligations. They do not 

establish binding rules or requirements and are not fully determinative of the issues addressed. 

Agency decisions in any particular case will be made applying the law and regulations on the 

basis of specific facts and actual action.