Comment submitted by Ronald Marr, Minnesota Soybean Processors

The Minnesota Soybean Processors (MnSP) is a soybean crush plant that produces soybean oil, soybean meal and other related products. Approximately one-half of the soybean oil produced is refined into biodiesel. As such MnSP has a special interest in this Direct Final Rule. MnSP believes that section 80.1129(b)(4) needs further clarification within the rule to fully define the intent of this section as provided in the description of this section under the RFS Program Amendments on page 57250 of the rulemaking. MnSP is currently receiving questions from numerous customers of B100 biodiesel (or B99.9 biodiesel) regarding their ability to now purchase biodiesel from a biodiesel producer without RINs attached since the consumer intends on selling the purchased B100 or B99 as motor fuel, thus adhering to this rule section. MnSP believes the intend of the rule is to allow any party directly selling neat biodiesel B100 or B99 directly into a motor vehicle supply tank to separate the RINs that have been assigned to the neat biodiesel and asks the Agency to further clarify this section of the rule to reflect this. The rule needs to identify that the biodiesel must be sold as a neat fuel (not to be further blended with petroleum diesel) deposited directly into a motor vehicle fuel supply tank as motor vehicle fuel.