The RFS program prohibits a party from generating RINs if the renewable feedstock used to make the renewable fuel was acquired from another party. Any RINs acquired with the renewable feedstock (e.g., ethanol) must be assigned to the renewable fuel product (e.g., ETBE) made from that feedstock.

If the ethanol used to make ETBE does not have RINs associated with it (i.e. the RINs have been properly separated prior to receipt of the ethanol by the ETBE producer), then the ETBE producer would neither generate RINs for the ETBE it producers, nor assign any RINs to that ETBE. Thus there is no need for an Equivalence Value for ETBE. See regulation Section 80.1126(d)(8).

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)