As the Renewable Fuel Standard continues to evolve in 2026, the Efficient Producer Petition (EP3) process remains an important opportunity for ethanol facilities looking to maximize their RIN generation potential. EP3 allows producers to generate RINs on volumes beyond their grandfathered 2007 permitted capacity when they can demonstrate improved greenhouse gas (GHG) performance. Corn starch ethanol volumes produced through approved EP3 pathways are eligible to generate D6 RINs, while grain sorghum ethanol produced through an advanced EP3 pathway may qualify to generate D5 RINs, provided the applicable EPA pathway requirements are met.
With the EPA finalizing 2026–2027 “Set 2” standards and the reallocation of Small Refinery Exemptions (SREs), efficient production has become more valuable than ever. At RINSTAR, we’ve outlined how producers can prepare a strong EP3 petition that clears the EPA’s technical and administrative review the first time.
1. Verify Eligibility and Pathway Alignment
The EP3 process is an expedited pathway, but it is strictly limited. Before drafting, ensure your facility fits the current “Efficient Producer” criteria:
- Production Process: Must use a dry mill ethanol process.
- Feedstocks: Restricted to corn starch, corn kernel fiber, or grain sorghum kernels.
- Co-products: Must produce distillers grains (DDGS) intended for animal feed.
- Process Energy: Limited to grid electricity, natural gas, coal, or specific approved biogases/biomasses.
2. Master the Technical Justification
The heart of your petition is the Technical Justification. This section should be concise (1–2 paragraphs) but must explicitly link your facility’s specific engineering upgrades to the required 20% GHG reduction below the 2005 baseline.
Technical elements to include:
- Specific Technologies: Highlight efficiency measures like LED lighting, advanced grind technologies, or high-efficiency motors.
- Energy Balance: Reference your 365-day rolling average energy consumption vs. fuel output.
- Registration Status: Summarize the status of your facility’s registration for D-code 3 (cellulosic) or D-code 6 (conventional) RINs.
Technical Justification Template
Section 1 of Template: Facility Overview and Scope
The (Facility Name), located in (City, State), is a dry mill ethanol production facility. This petition is submitted to demonstrate that ethanol produced at this facility using (Corn Starch / Grain Sorghum / Both) achieves the 20% greenhouse gas (GHG) reduction threshold required for “Efficient Producer” status under §40 CFR 80.1416. The facility utilizes a highly optimized production process that consistently operates below the maximum lifecycle GHG threshold of 78.56 kgCO2e/MMBtu.
Section 2 of Template: Efficiency Technologies
The facility achieves higher GHG performance through a combination of thermal and mechanical efficiencies, including but not limited to:
- Advanced Feedstock Processing: Implementation of technologies such as Selective Milling Technology (SMT) or hammer mill upgrades to improve starch availability and reduce energy use during the liquefaction phase.
- Thermal Integration: Deployment of systems such as multi-effect evaporation or regenerative thermal oxidizers (RTOs) to capture and reuse waste heat from distillation, helping pre-heat slurry and significantly reduce natural gas consumption.
- Mechanical Reliability: Installation of equipment such as variable frequency drives (VFDs) or high-efficiency centrifuges to lower parasitic electrical load per gallon of denatured ethanol produced.
- Co-Product Management: Use of efficient systems such as corn oil extraction technology to enhance the facility’s carbon intensity (CI) score by increasing the energy value of co-products while maintaining DDGS quality.
* Please only add information that is applicable to your operation. These are examples *
Section 3 of Template: Energy and Mass Balance Summary
Based on the EPA Efficient Producer GHG Calculator (Version 1.4), our facility maintains a 365-day rolling average fuel yield of (Insert Yield) gallons of undenatured ethanol per bushel of corn. Our current energy intensity is approximately (Insert BTU value) BTUs of natural gas and (Insert kWh value) kWh of electricity per gallon.
These metrics, documented in the attached mass balance data, demonstrate a total lifecycle GHG reduction of (Insert Calculation) compared to the 2005 baseline. This provides a safety margin of (Insert Margin) to ensure continuous compliance.
Tips for Customizing This Template:
- Focus on “The Why”: If you recently installed a specific piece of equipment (like a new boiler or molecular sieve), mention it by name. The EPA likes to see that the efficiency is the result of intentional engineering, not just a “good year” for corn quality.
- Consistency is Key: Ensure the numbers you put in the template match the GHG Calculator spreadsheet exactly. Discrepancies between the narrative and the data are the #1 cause of “Requests for Information” (RFIs) that delay approval.
3. Use the Latest GHG Calculator (Version 1.4)
As of late 2025 / early 2026, the EPA utilizes Version 1.4 of the Efficient Producer GHG Calculator. This tool uses pre-determined emission factors to calculate whether your facility meets the threshold.
Tip: Your lifecycle GHG emissions must not exceed 78.56 kgCO2e/MMBtu to qualify. If your facility is hovering near this ceiling, document additional buffers through process efficiency to prevent future non-compliance during fuel-price or production-load fluctuations.
4. Structure the Submission Package
The EPA rejected numerous petitions in 2025 due to formatting errors. To ensure an “Efficient” review, organize your petition as follows:
| Section | Content Requirements |
|---|---|
| Cover Sheet | Single page; no Confidential Business Information (CBI); includes facility name, location, and POC (Person of Contact). |
| Feedstock | Certified statement that only corn/grain sorghum is used. |
| Production Process | Description of the dry mill process and energy sources. |
| GHG Analysis | The completed GHG Calculator spreadsheet and supporting mass balance data. |
| CBI Version | A full version with sensitive data (e.g., proprietary yields) highlighted. |
| Redacted Version | A “Public” version for EPA’s website with all CBI blacked out. |
5. Navigating the Submission Channels
In 2026, the EPA prefers that submissions be completed electronically through the CDX DCFUEL reporting system. This encrypted portal provides a more secure method for handling Confidential Business Information (CBI) than email. We have previously outlined the steps for registering for a CDX account.
- Option 1 (CDX): Select “RFS Pathway Petitions (40 CFR 80.1416) on the Certify Reports page.
- Option 2 (Email): Send to rfspathways@epa.gov. If using this route, ensure all CBI headers are correctly marked (e.g., “CONTAINS CBI” in the header of every page).
6. Post-Approval: The 365-Day Rolling Average
An approved petition is not a “set and forget” document. To maintain your status, you must calculate and record your GHG emissions on a 365-day rolling average. If your efficiency dips, perhaps due to a cold winter increasing thermal loads or equipment downtime, you must stop generating RINs for the “excess” volume until the average returns below the 78.56 kgCO2e/MMBtu threshold.
How RINSTAR Can Help
Preparing and submitting an Efficient Producer Petition requires more than just completing the paperwork. It demands accurate data, consistent recordkeeping, and ongoing monitoring to maintain approval. That’s where RINSTAR makes the difference.
- Stay Organized: Centralize mass balance data, GHG calculations, and supporting documentation so your EP3 petition and ongoing records remain audit-ready.
- Ensure Accuracy: Automated tracking tools help align production data with GHG calculator inputs, reducing discrepancies that can trigger EPA Requests for Information.
- Monitor Compliance: Track your 365-day rolling average and key efficiency metrics to ensure continued eligibility for generating RINs on excess volumes.
- Expert Guidance: With more than 15 years of RFS experience, our team helps producers navigate EPA requirements, submission best practices, and post-approval obligations with confidence.
With RINSTAR, you gain more than a compliance platform, you gain a trusted partner dedicated to keeping your facility efficient, compliant, and prepared for what’s next under the Renewable Fuel Standard.
📩 Have questions? Reach out at services@cfch.com or schedule a demo to learn how RINSTAR can support your EP3 and RFS compliance strategy.
Disclaimer:
The information and referenced links in this article are accurate as of the publication date. Renewable Fuel Standard requirements, EPA guidance, and related regulatory processes are subject to change at any time at the EPA’s discretion. Readers should verify current rules and guidance before taking action based on this content.
