A. Un-denatured ethanol is not a renewable fuel. See 80.1101(d)(3). Under the described scenario, the party to whom custody is transferred and who denatures the ethanol would be producer of the renewable fuel.
B. Under the described scenario, RINs would be generated by the party who denatures the ethanol and produces the renewable fuel. See 80.1126(d). If the petroleum refiner wishes to generate RINs, then the petroleum refiner would have to keep title to the ethanol throughout the described transaction.
Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (PDF) (55 pp, 221 K, EPA420-F-07-041a, August 2007, About PDF)