For grandfathered facilities, only the baseline volumes are exempt from the 20 percent GHG reduction requirement Thus, RINs may be generated for baseline volumes of fuel regardless of lifecycle greenhouse gas emissions performance.

Volumes of fuel produced above the baseline volume must meet the 20 percent GHG reduction requirement to qualify for RIN generation under RFS. Table 1 to 80.1426 contains several approved pathways through which corn ethanol produced above the baseline volume can generate RINs.