[icambron]

Lot of assumptions on this thread. The company involved here is claiming that hasn't committed a crime, which isn't a very interesting claim. The agency that's launched and investigation hasn't gotten a chance to, you know, conduct that investigation yet. There's also a possibility that this was all a mistake that just needs sorted out. So before we all jump on the incentives-gone-wrong and government-is-inefficient trains, maybe give the government a chance?

But if we are going to speculate--and let's face it, we are--let's at least have a gander at the relevant regulations. IANAL, etc, but from my reading Title 40 Part 80 Subpart M [1] it seems really unlikely that assigning the same volume of fuel different RINs is legal. There's a bunch there about assigning specific numbers to specific volumes of fuel, but there's also the super specific:

> (5) Importers shall not generate RINs for renewable fuel that has already been assigned RINs by a registered foreign producer.[2]

Sounds pretty clear.

[1] http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=27e92597...

[2] http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=27e92597...