Author Archives for raeditor
September 28, 2025 10:55 am
Published by raeditor
The complex and frequent regulatory shifts within the federal Renewable Fuel Standard (RFS) program are the primary drivers of volatility in Renewable Identification Number (RIN) prices, and we’ve all been stuck riding the RIN rollercoaster. RINs are the compliance currency and market incentive of the RFS, and it’s crucial your company understands how to value and plan your RINs. When the Environmental Protection Agency (EPA) or Congress signals a potential change in RFS policy, such as delays in setting Renewable Volume Obligations (RVOs), the granting of Small Refinery Exemptions (SREs), or proposals for market-altering reforms (like a price cap), it... Read More →
September 16, 2025 8:44 am
Published by raeditor
On September 16, 2025, the U.S. Environmental Protection Agency (EPA) did little to shed light on how small refinery exemptions (SREs) from 2023-2025 will be reallocated. While proposing two approaches — a 100% and a 50% reallocation of exempted volumes — EPA indicated it would entertain other allocations. The specifics of EPA’s proposal were detailed in a Supplemental Notice of Proposed Rulemaking to revise the proposed Renewable Fuel Standard (RFS) “Set 2” volume requirements for 2026 and 2027. It follows on the Agency’s August 22 Small Refinery Exemption (SRE) decisions. In a strongly worded news release that accompanied the proposal, EPA... Read More →
August 22, 2025 8:57 am
Published by raeditor
This morning, EPA announced its decision regarding 175 small refinery petitions sitting before it. These petitions were for compliance years 2016-2024. EPA is granting a full exemption to 63 petitions, granting partial, or half, exemptions to 77 petitions, denying 28 petitions, and determining 7 petitions to be ineligible. In addition to this decision, EPA makes a lengthy argument as to where judicial review of each petition should take place, coming to the conclusion the “final actions discussed within the August 2025 SRE Decisions Action are based on determinations of nationwide scope or effect for purposed of CAA section 307(b)(1) and... Read More →
June 13, 2025 9:50 am
Published by raeditor
Today, the Environmental Protection Agency (EPA) issued the long-awaited proposed renewable volume obligations (RVOs) for 2026 and 2027 under the Renewable Fuel Standard (RFS), as well as the final rule regarding the partial waiver of the 2024 Cellulosic Biofuel Volume Requirements. For the proposed rule, EPA set the RVOs at 24.02 billion Renewable Identification Numbers (RINs) of renewable fuel in 2026, and 24.46 billion RINs in 2027. 2026 RVOs are an increase of 1.69 billion RINs over 2025 requirements. EPA is also considering a waiver for the 2025 mandate for cellulosic biofuel. Since RVOs set demand for RINs, the announcement... Read More →
September 11, 2024 9:41 am
Published by raeditor
So, a bit of background. Most of you are already familiar with the Renewable Fuel Standard (RFS) and Small Refinery Exemptions (SRE). If you are not, please be sure to read up on them in previous posts. Now that that’s done, let’s look at the issue at hand. In 2022, EPA denied all SREs that had been petitioned. The Agency reasoned that only compliance costs with the RFS were relevant to showing disproportionate economic harm, and these costs could simply be passed along to their consumers. As such, EPA concluded that small refineries do not face any economic hardship via... Read More →
December 11, 2023 9:51 am
Published by raeditor
Did you know that if you totaled up all the birds and pear trees given in the song “The Twelve Days of Christmas”, there would be 184 birds and 12 trees? Speaking of gifting others, the 5th Circuit Court of Appeals recently gave refiners the “gift” of withdrawing EPA’s denial of small refinery exemptions (SREs) for six different refineries. How did this “gift” come to be? In 2022, EPA made headlines twice when it retroactively overturned SRE petitions that had already been granted. In April 2022, EPA retroactively denied 36 SRE petitions from 36 different small refineries that had... Read More →
November 6, 2023 4:20 pm
Published by raeditor
My dad was the person in my family handing down the life lessons. One thing that I heard probably more than anything else was that there are only three certainties in life: death, taxes, and the fact that everything changes. Turns out he was right…though it will be a very long time before I tell him that…Speaking of taxes, recently, Chemoil Corp. ran into one of the more certain things in life. I know, I know, taxes….blech. I promise, however, to give you a scintillating tale of a tax credit, a bad actor, and a court case. I am certain... Read More →
October 11, 2023 9:34 am
Published by raeditor
It’s spooky season! A time filled with ghosts and goblins and…a report by the Office of Inspector General (OIG) on fraud potential within the Renewable Fuel Standard (RFS). Recently, OIG completed an audit of the RFS to identify areas of improvement to prevent opportunities for RIN fraud. The words “fraud” and “Renewable fuel Standard” or “RINs” used in the same sentence can be a little scary. I’ll admit it. When this report was first published, before I had read it, I passed it on to my boss with the message: “This doesn’t look good.” Even some of the headlines that... Read More →
September 11, 2023 9:47 am
Published by raeditor
September in Iowa is just starting to feel a bit like fall. I am so ready for comfy socks, oversized sweatshirts, pumpkin spice, and the feeling of impending lawsuits…wait, what? EPA has recently “fallen” subject to many lawsuits filed by many different entities from several different market positions, but this post is going to focus on the one between EPA and the Center for Biological Diversity. Recently, the Center for Biological Diversity (CBD) filed suit against EPA for the Renewable Volume Obligations (RVOs) as part the Renewable Fuel Standard (RFS) “Set” rule released this past June. More specifically, CBD is... Read More →
August 8, 2023 2:15 pm
Published by raeditor
I think there needs to be a book like “Alexander and the Terrible, Horrible, No Good, Very Bad Day,” but for adults. Maybe, “Alexander and the Terrible, Horrible, No Good, Very Bad Adulting,” complete with an accurate description of the 40-hour work week, taxes, and what paying student loans feels like. Given recent events, small refineries might be able to relate to either book. Within the past month, EPA has made a couple of decisions that have gained a fair amount of attention. First, EPA denied 26 Small Refinery Exemptions (SRE) petitions between the years 2016-2018 and 2021-2023. Second, the... Read More →
