Author Archives for Rhonda O'Connor

RFS Whiplash: Newest Challenges to SREs, Proposal to Reallocate 100% of Waived Gallons

October 14, 2026 8:00 am Published by Comments Off on RFS Whiplash: Newest Challenges to SREs, Proposal to Reallocate 100% of Waived Gallons

A petroleum refiner, a biofuel producer, and a farmer share a meal at a restaurant. When the check comes, they all argue over how to split the tab. This is a great analogy for the fight over Small Refinery Exemptions (SREs). They are all Renewable Fuel Standard (RFS) participants, and between EPA waivers and reallocations followed by court rulings, the tab is passed back and forth between refineries or biofuel producers and the farm groups who supply the feedstock. Petroleum refiners see SREs as a way to help small refineries that can’t absorb RFS compliance costs the way larger ones... Read More →


EPA Announces Two Possible Options for 100% Reallocation for 2025 Small Refinery Exemption Volumes

October 13, 2026 3:22 pm Published by Comments Off on EPA Announces Two Possible Options for 100% Reallocation for 2025 Small Refinery Exemption Volumes

October 13, 2026 – U.S. Environmental Protection Agency (EPA) announced revisions to the Renewable Fuel Standard (RFS) Set 2 rule volumes due to recent SRE decisions. EPA proposed two options to reallocate 100% of the difference between projected and actual exempted volumes for 2025 Small Refinery Exemptions (SREs), which totals 770 million RINs worth of renewable fuels. Approach One: Divide the additional volume equally between the 2026 and 2027 compliance years. Approach Two: Reallocate all the additional to the 2027 compliance year. EPA is taking public comments on the proposal until Dec. 4, 2026, so neither approach is set in... Read More →


EPA’s Compliance Deadline Extension: Why It Doesn’t Impact All RFS Participants

September 16, 2026 8:00 am Published by Comments Off on EPA’s Compliance Deadline Extension: Why It Doesn’t Impact All RFS Participants

It can be confusing for participants in the Renewable Fuel Standard (RFS) to determine which deadline extensions apply, and how they impact them. For non-Obligated Parties, such as renewable fuel blenders and producers, EPA’s recent deadline extension might impact their RIN management strategy – but it does not impact their compliance deadlines. Who’s Impacted by the Deadline Extension? And Why? Obligated Parties are required to retire RINs in quantities that meet EPA’s Renewable Volume Obligation (RVO) for the year. These are more commonly referred to as blending mandates. If EPA is delayed in setting the blending mandates or EPA modifies... Read More →


EPA Issues Several Decisions Impacting RINs: 2025 SRE Decisions, Reallocation Plans and Compliance Deadline Extension for Obligated Parties

August 31, 2026 3:44 pm Published by Comments Off on EPA Issues Several Decisions Impacting RINs: 2025 SRE Decisions, Reallocation Plans and Compliance Deadline Extension for Obligated Parties

On Aug. 31, 2026, the U.S. Environmental Protection Agency (EPA) issued decisions on 34 petitions from small refineries for exemptions from the Renewable Fuel Standard (RFS) for 2025, while proposing to reallocate 100 percent of the difference between the projected and actual exempted volumes for 2025 SREs into the 2026-27 RVO by the end of October. Lastly, EPA announced it will once again extend the 2025 RFS compliance deadline for obligated parties, moving it from Sept. 1 to Oct. 1, 2026. For the SRE decisions, EPA is granting the following: Full (100 percent) exemptions: 18 petition Granting partial (50 percent) exemptions: 11 petitions Denying: 3 petitions... Read More →


RFS Blending Targets Challenged in Court

August 12, 2026 8:38 am Published by Comments Off on RFS Blending Targets Challenged in Court

In March 2026, EPA released record high 2026-2027 blending obligations under the Renewable Fuel Standard (RFS). These record high targets quickly became the subject of a lawsuit in the U.S. D.C. Circuit Court of Appeals – with parties filing suit from all directions.  How the court rules with respect to these challenges will directly shape how EPA sets future renewable volume obligations (RVOs) and could impact demand for the current year targets under consideration. The Rule at Center of the Fight Since EPA announced the Set 2 Rule, impacted parties are choosing a side when it comes to this challenge... Read More →


EPA Issues Decisions on 2023 & 2024 SRE Applications: Maps Out Process for Future SRE Decisions & Implementation

August 3, 2026 2:28 pm Published by Comments Off on EPA Issues Decisions on 2023 & 2024 SRE Applications: Maps Out Process for Future SRE Decisions & Implementation

On Aug. 3, 2026, the U.S. Environmental Protection Agency (EPA) issued decisions on 6 petitions from small refineries for exemptions from the Renewable Fuel Standard (RFS) for 2023 and 2024. EPA is granting the following: Full (100 percent) exemptions: 1 petition Granting partial (50 percent) exemptions: 2 petitions Denying: 0 petitions Declaring Ineligible: 3 petitions The exemptions granted apply only to the 2024 compliance year and total 160 million exempted Renewable Volume Obligation (RVO) RINs; no exempted volume was awarded for 2023, where both petitions considered were the ineligible ones. RINs to be Returned, Not Reissued For refineries that already retired RINs... Read More →


Why Do RINs Get Retired?

August 3, 2026 8:00 am Published by Comments Off on Why Do RINs Get Retired?

Think about the last time you returned something to a store. The cashier always asks why: wrong size, changed your mind, item defective. The refund happens either way, but the reason gets logged. RIN retirement works the same way. Once a RIN is retired, it’s gone; it can’t be traded or used again. But EPA also wants to know why it was retired. One of the biggest reasons RINs get retired is to satisfy the annual Renewable Volume Obligation (RVO).  Obligated parties retire RINs to show blending targets were met. Per RFS Code an obligated party is defined as any... Read More →


Does Renewable Fuel Used in Data Centers Qualify for RINs?

July 30, 2026 8:13 am Published by Comments Off on Does Renewable Fuel Used in Data Centers Qualify for RINs?

Here’s What the Renewable Fuel Standards Says The short answer is no – and with data centers consuming energy at record levels, it’s worth understanding exactly why. As companies race to power AI infrastructure and cloud computing with renewable energy, a reasonable question has started to circulate:  If we supply renewable fuel to run a data center, is that fuel eligible for RINs under the Renewable Fuel Standard?  This use feels like it should qualify. The fuel is renewable. The use is real. But under the RFS, how the fuel is used matters – and data centers or stationary power... Read More →


Beyond the BTC: What 45Z Means for Biodiesel Blenders

July 15, 2026 9:00 am Published by Comments Off on Beyond the BTC: What 45Z Means for Biodiesel Blenders

The expiration of the Biodiesel Blender’s Tax Credit (BTC) at the end of 2024 and its replacement by the Section 45Z Clean Fuel Production Credit has been characterized as a policy upgrade – a more sophisticated, carbon emissions-based framework that is renewable fuel neutral. While that characterization has some merit for renewable fuel producers, the picture is less favorable for downstream biodiesel blenders. Under the BTC, blenders had a path to the credit value – sometimes negotiated through the purchase of B99 – but it was real. Under 45Z, that path is murky at best. What was once a fixed,... Read More →


Choosing the Right Reason for a RIN Trade (and Why It’s Simpler Than You Think)

May 13, 2026 7:00 am Published by Comments Off on Choosing the Right Reason for a RIN Trade (and Why It’s Simpler Than You Think)

Selecting the right reason for a RIN trade is like ordering a meal for dine in or to go at a restaurant. Seems simple, right? Same food, but very different handling. Reasons for RIN trades work the same way. Spot, Term, Consignment, and Standard don’t change what you’re selling; they describe how the deal is structured. Once you understand what each one is actually describing, picking the right one becomes very straightforward. The Common RIN Trade Types You Need to Know Each time you sell RINs, you’ll select one of four primary trade types when entering the transaction. Each corresponds... Read More →