An Entertaining 101 on Issues Impacting the Renewable Fuel Standard

The Responsible Corporate Officer: The Pivotal Position within the EPA’s Renewable Fuel Standard

January 12, 2026

If you participate in the Renewable Fuel Standard (RFS) program, whether as a renewable fuel producer, obligated party, exporter, or other regulated entity, you are required to designate a Responsible Corporate Officer (RCO) with the U.S. Environmental Protection Agency (EPA). The RCO plays a pivotal role in ensuring the accuracy, legality, and integrity of all compliance activities under the RFS. But what exactly does it mean? And who is eligible to serve in this role? Below, we break down the essentials. What Is a Responsible Corporate Officer (RCO)? The Responsible Corporate Officer is the individual legally accountable for the information... Read More →

A Brief History of the RFS: How It Started and How It Has Evolved Across Administrations

December 5, 2025

Understanding how the Renewable Fuel Standard (RFS) began, how much the program has changed, and why it even exists in the first place can be challenging. The RFS didn’t simply appear fully formed. It has been reshaped repeatedly by Congress, the courts, market forces, and each presidential administration. Taking a step back to understand the evolution helps explain many of the complexities we navigate today. Origins: Energy Security, Rural Development, and Early Biofuel Policy The RFS was enacted with the Energy Policy Act of 2005 (EPAct), which is rooted in Section 211(o) of the Clean Air Act. At the time,... Read More →

What the SRE Reallocation Fight Means for the RFS

October 15, 2025

EPA has moved to address how to account for billions of gallons of renewable fuel blending obligations that were waived by Small Refinery Exemptions (SREs). The Agency’s supplemental proposal would either fully or partially (50%) reallocate those waived volumes into future Renewable Volume Obligations (RVOs)—a move that would directly increase demand for biofuels (and RINs) if added to the increases for biofuels in the proposed 2026–2027 RVOs. This proposal has once again pitted importers and refiners against the agricultural and biofuels sectors. Background — How We Got Here SRE authority was created within the Renewable Fuel Standard (RFS) framework to... Read More →

How to Manage the RIN Rollercoaster

September 28, 2025

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 →

Biodiesel vs. Renewable Diesel: Are They the Same or Different?

September 5, 2025

As the demand for low-carbon fuel alternatives grows, the market is expanding beyond traditional petroleum products—and with it, so is the complexity. Two of the most prominent contenders in the renewable fuels landscape are biodiesel and renewable diesel. Though they may sound similar and serve a similar purpose, they differ in terms of production, chemistry, performance, and regulatory treatment. Production Pathways and Chemical Composition Biodiesel is produced via transesterification, a chemical reaction involving vegetable oils or animal fats with an alcohol (usually methanol) in the presence of a catalyst. Common feedstocks include soybean oil, canola oil, used cooking oil, and... Read More →

What Are Renewable Volume Obligations (RVOs)?

August 21, 2025

For anyone involved in blending biofuels, understanding Renewable Volume Obligations (RVOs) under the U.S. EPA Renewable Fuel Standard (RFS) is essential. RVOs are annual mandates set by EPA that require refiners and importers of gasoline and diesel to blend specific volumes of renewable fuel into the nation’s fuel supply. RVOs set the demand for RINs for each compliance year and serve as the enforcement mechanism for the RFS. How RVOs Work Understanding how RVOs work involves several key steps: Step One: EPA Sets the National Targets Each year, EPA sets national renewable fuel volume targets. These targets are divided into... Read More →

Two Landmark Court Rulings Have the Potential to Reshape the Future of the Renewable Fuel Standard

July 16, 2025

Two major federal court decisions—one from the U.S. Supreme Court and the other from the D.C. Circuit Court of Appeals—are poised to significantly impact the administration and future direction of the Renewable Fuel Standard (RFS), EPA’s signature biofuel blending program. Supreme Court Centralizes Refinery Waiver Disputes In a 7–2 ruling, the U.S. Supreme Court determined that legal challenges over EPA’s denial of small refinery exemptions (SREs) must be heard exclusively by the U.S. Court of Appeals for the D.C. Circuit. The Court held that EPA’s mass denial of SRE petitions was rooted in a nationwide policy judgment—that most refiners can... Read More →

Understanding EPA’s Summertime Emergency Waiver for E15

June 17, 2025

In an effort to “address fuel supply challenges and support domestic agriculture” this summer, the U.S. Environmental Protection Agency (EPA) is issuing emergency waivers to allow the nationwide sale of E15 gasoline during the summer months. While this is the fourth successive summer in which EPA has issued this type of emergency fuel waiver, there was a new hurdle this year compared to years past. Earlier this year, EPA granted requests from eight Midwestern states to revoke the 1-psi Reid Vapor Pressure (RVP) waiver for E10 during the summer months, aiming to make E15 more widely available by eliminating the... Read More →

RVP and the Year-Round Sale of E15: What’s Happening?

April 16, 2025

Midwest states have long championed the use of E15—a gasoline blend containing 15% ethanol—for its promise to lower fuel costs, reduce greenhouse gas emissions, and support rural economies. However, efforts to enable year-round sales of E15 have faced many regulatory hurdles and push back for over a decade. What Is RVP? Reid Vapor Pressure (RVP) is a measure of how easily gasoline evaporates, indicating the fuel’s volatility. This matters because more volatile fuels evaporate faster, especially in warm weather, which can contribute to the formation of ground-level ozone, or smog. To protect air quality—particularly in the summer when ozone pollution... Read More →

Supreme Court to Hear Case with Potential to Reshape Legal Landscape of RFS

January 14, 2025

The U.S. Supreme Court has recently agreed to hear a critical case which could reshape the legal landscape of the Renewable Fuel Standard (RFS) and its authority. The case, Environmental Protection Agency v. Calumet Shreveport Refining, LLC, Case No. 23-1229, centers around a pivotal question regarding the jurisdiction for reviewing denials of small refinery exemptions (SREs) under the RFS. This decision, once rendered, could have far-reaching implications for both the future of the RFS and the authority of the U.S. Environmental Protection Agency (EPA) in implementing environmental policy related to biofuels. Background: The Renewable Fuel Standard and Small Refinery Exemptions... Read More →