Estimating Carryover RINs Available for Use in 2014

Dallas Burkholder, Office of Transportation and Air Quality, US EPA

November 2015

Summary

As a result of the delay in establishing the 2014 RFS standards, EPA has also delayed the 

2013 compliance deadline. The precise number of 2013 RINs that will be available for use 

by obligated parties towards the 2014 standards (carryover RINs) is therefore not known. 

It is possible, however, to estimate the number of carryover RINs available for use in 2014 

based on the data available at this time. In general, this can be done by first calculating the 

number of 2012 RINs available for use towards satisfying the 2013 obligations based on 

the 2012 compliance information. We then compare the number of RINs available for 

compliance in 2013, including both RINs generated in that year and 2012 carryover RINs 

available for use towards the 2013 standard, to the RFS standards for 2013. The difference 

between these two sums is our estimate of the potentially available 2013 carryover RINs 

for use in 2014. In this final rule we are establishing the RFS standards for 2014 and 2015 

at levels equal to our projection of renewable fuel supply in these years. This means that 

we do not expect that the number of carryover RINs available will increase or decrease as 

obligated parties comply with the 2014 and 2015 standards, and therefore the number of 

carryover RINs available for use in 2014 will be approximately equal to the number of 

carryover RINs available for use in 2016.

Calculating the Number of 2012 Carryover RINs Available for Use in 2013

To calculate the number of 2012 carryover RINs available for use in 2013 we begin with 

the number of 2012 RINs that are currently available for use (RINs that have not been 

retired), as indicated in EMTS. This information is shown in Table 1 below.

Table 1

2012 RINs that Have Not Been Retired

D3 RINs D4 RINs D5 RINs D6 RINs D7 RINs

20,069 176,664,744 121,157,993 1,505,125,791 1,741

The number of 2012 RINs that may be used for 2013 compliance is not, however, simply 

equal to the number of 2012 RINs that are currently available for use. This is because some 

obligated parties have already retired 2012 RINs in EMTS towards their 2013 compliance 
obligations.1 The total number of 2012 RINs projected to be available for use towards 

satisfying the 2013 RFS obligations is equal to the sum of the 2012 RINs that EMTS 

indicates are currently available, plus the 2012 RINs already retired towards 2013 RFS 

obligations. These numbers are shown in Table 2 below, along with the sum of the two 

numbers which is the total number of 2012 RINs that can be used for compliance in 2013. 

We also compare the total number of 2012 carryover RINs for each category to 20% of the 

2013 standards to see if the 20% carryover limit will impact the use of any 2012 carryover 

RINs in 2013 in Table 3. The 20% carryover limit is not constraining for any of the RIN 

categories.

Table 2

Total Number of 2012 RINs Available For Use Towards Meeting the 2013 Obligations

D3 RINs D4 RINs D5 RINs D6 RINs D7 RINs

Available 2012 RINs 20,069 176,664,744 121,157,993 1,505,125,791 1,741

2012 RINs Retired

To Meet 2013 

Obligations 0 91,796,832 46,144,741 618,115,597 0

Total 2012 Carryover 

RINs 20,069 268,461,576 167,302,734 2,123,241,388 1,741

Table 3

2012 Carryover RINs and 2013 Carryover Limits

Total 

Cellulosic 

RINs (D3+7)

Total BBD 

RINs (D4)

Total Advanced 

RINs 

(D3+D4+D5+D7)

Total Renewable 

Fuel RINs (all D 

codes)

Total 2012 

Carryover RINs 21,810 268,461,576 435,786,120 2,559,027,508

2013 Standards 810,185 1,920,000,000 2,750,000,000 16,550,000,000

2013 Carryover 

Limit (20% of 

Standard) 162,037 384,000,000 550,000,000 3,310,000,000

Carryover RIN Use 

Limited by Cap? No No No No

Estimating the Number of 2013 Carryover RINs Available for Use in 2014

Unlike in 2012, the compliance deadline has not yet passed for 2013, so we must estimate, 

rather than calculate, the number of 2013 RINs available to be used for compliance with the 

2014 standards after meeting the 2013 standards. To estimate the number of carryover 

RINs available for use in 2014, we first added the number of 2012 carryover RINs available 

 

1 The number of 2012 RINs retired for 2013 compliance is available in the EMTS system, however this data is not 

publicly reported
for use in 2013 to the number of RINs generated in 2013. We then subtract the RINs that 

were retired for reasons other than compliance with the 2013 standards (adjustments), 

and the RINs which must be retired for exported biofuel. These calculations are shown in 

Table 4 below.

Table 4

Estimating RINs Available for 2013 Compliance

Total 

Cellulosic 

RINs (D3+7)

BBD RINs 

(D4)

Advanced 

Biofuel RINs 

(D5)

Conventional 

Renewable Fuel 

RINs (D6)

2012 carryover 

RINs Available for 

Use in 2013 21,810 268,461,576 167,302,734 2,123,241,388

RINs Generated in 

2013 818,517 2,739,133,319 557,824,688 13,350,496,387

RINs Retired for 

Non-Compliance 

Purposes 8,332 100,773,533 6,316,175 108,158,411

RINs Expected to 

Be Retired for 

Exported Biofuel 0 297,554,287 0 407,399,931

Total RINs 

Available for 

Compliance in 

2013 831,995 2,609,267,075 718,811,247 14,958,179,433

Finally, we compared the number of RINs available for use in 2013 (including both 2012 

carryover RINs and RINs generated in 2013, minus RINs retired for non-compliance 

reasons and RINs retired for exported biofuel) to the 2013 standards. The difference 

between these two numbers, shown in Table 5 below, is equal to the estimated number of 

2013 carryover RINs available for use in 2014.
Table 5

Estimated number of 2013 Carryover RINs Available for Use in 2014

Total 

Cellulosic 

RINs (D3+7)

Total BBD 

RINs (D4)*

Total Advanced 

RINs 

(D3+D4+D5+D7)

Total Renewable 

Fuel RINs (all D 

codes)

Total RINs 

Available in 2013 831,995 2,609,267,075 3,328,910,317 18,287,089,750

2013 Standards 810,185 1,920,000,000 2,750,000,000 16,550,000,000

2013 Carryover 

RINs Available in 

2014 21,810 689,267,075* 578,910,317 1,737,089,750

*This calculation assumes that no BBD RINs are retired in excess of the BBD standard. In practice additional 

BBD RINs are expected to be retired to satisfy obligated parties advanced and total renewable fuel 

obligations. The total number of carryover BBD RINs will not exceed the number of total advanced carryover 

RINs calculated in this table.

These calculations indicate that approximately 1.74 billion carryover RINs generated in 

2013 would be available for use towards meeting the 2014 RFS standards. Of these 1.74 

billion RINs, we estimate that approximately 579 million of these are advanced biofuel 

RINs (D3, D4, D5, or D7). We estimate that the majority of these 579 million advanced 

biofuel RINs are BBD RINs. While Table 5 above shows a difference of approximately 689 

million BBD RINs between the amount available and the amount needed to satisfy the 2013 

standards, in reality we do not know precisely how many BBD RINs were retired in excess 

of the BBD standard to comply with the 2013 advanced and total standards. We do know, 

however, that the total number of RINs available that can be used towards the advanced 

biofuel standard is approximately 579 million, and therefore the number of BBD RINs 

available cannot exceed this number. Because we are establishing RFS standards for 2014 

and 2015 that are projected to be equal to the number of RINs available for compliance in 

these years, we anticipate that approximately 1.74 billion carryover RINs will also be 

available for compliance in 2016. 

We note, however, that there are several factors that may reduce the number of carryover 

RINs that are available for compliance with the 2016 standards. A small number of 

obligated parties forward RIN deficits from 2012. Satisfying these deficits will require the 

retirement of additional RINs beyond the number required by the 2013 standards. Any 

additional RINs retired to satisfy deficits carried forward into 2013 would result in fewer 

carryover RINs being available in for 2014, and thus for 2016. In addition, enforcement 

actions in previous years have required parties that generated invalid RINs, or relied on 

invalid RINs for compliance, to acquire valid RINs. The aggregate sum of such additional 

RIN purchases has totaled over 100 million RINs. Because it is not possible to generate 

additional RINs in 2014 and 2015, RINs retired due to new enforcement actions would 

effectively reduce the number of carryover RINs available for use in compliance with the 

2016 standards. The 2016 RINs retired due to enforcement actions would not technically 

need to be carryover RINs, but to the extent that 2016 vintage RINs were used for such 

purposes they would not be available for compliance with the 2016 standards, and 

obligated parties would need to rely on an equal number of carryover RINs to meet their 

2016 obligations. Because of these uncertainties, it is best to view our estimate of 1.74 
billion carryover RINs available for use in 2014, and therefore available for use in 2016, as 

the upper limit. The actual number of RINs available for compliance with the 2016 

standards may, in fact, be significantly less than this number.