For Obligated Parties who are subject to EPA's recent NOVs, please keep the following in mind when studying retired RIN replacement options, if you have also transferred invalid RINs to third parties:
80.1431(b)(3) - Any valid RINs remaining after invalid RINs are retired must first be applied to correct the transfer of invalid RINs to another party before applying the valid RINs to meet the party's Renewable Volume Obligations at the end of the compliance year.
Please contact Sandra Dunphy at 832-320-3218 or Sandra.Dunphy@WeaverLLP.com with any questions.