Only 2 errors on RIN calculation?

This isn't clear to me, my original calculation below may be fine as the RVO is on the mandates NOT the gaps.....

Text from EPA

To implement EISA’s restriction on

the life of credits and address the

rollover issue, the RFS1 final

rulemaking implemented a 20% cap on

the amount of an obligated party’s RVO

that can be met using previous-year

RINs. Thus each obligated party is

required to use current-year RINs to

meet at least 80% of its RVO, with a

maximum of 20% being derived from

previous-year RINs. Any previous-year

RINs that an obligated party may have

that are in excess of the 20% cap can be

traded to other obligated parties that

need them. If the previous-year RINs in

excess of the 20% cap are not used by

any obligated party for compliance, they

will thereafter cease to be valid for

compliance purposes.

Link to EPA rule making
http://www.gpo.gov/fdsys/pkg/FR-2010-03-26/pdf/2010-3851.pdf


Relevant Text