An Entertaining 101 on Issues Impacting the Renewable Fuel Standard

Sinclair v. EPA: When the RFS Looks Like an Existential Crisis

November 18, 2020

Have you ever taken a moment to think: how did I even get here? This is probably what EPA thinks on a daily basis: how did we get here? Last month, I wrote on the 10th Circuit case where EPA was held accountable for granting small refiner exemptions to entities that didn’t necessarily qualify for the waiver. To be able to have such broad authority, EPA had to get it from somewhere: meet Sinclair v. EPA (2017). To be fair to you guys, I kind of put the chicken before the egg last month by talking about the 10th Circuit case first. Keep in... Read More →

Preventing Headaches and Heartbreaks: the 10th Circuit Court Decision on Small Refinery Exemptions

October 14, 2020

There are somethings that just should not be repeated: headaches, heartbreaks…global pandemics, the year 2020…too soon? The 10 Circuit Court case that happened earlier this year is not one of those things. **DISCLAIMER** If you do not know what a small refinery exemption is or you do not understand what an RVO is, you will not understand this article. There are several articles on this page to help you understand those concepts. Read those articles first and then come back to this one. It’s a good time, I promise. Sometimes, it’s ok to skip over the facts….just like candidates running for... Read More →

Much Ado About Something: Why Everyone is Yelling About SRE’s

September 16, 2020

There are some things that people do, and we just fail to understand why. Putting pineapple on pizza or thinking pickles with peanut butter is a good idea, for instance. Sometimes, granting an entity a Small Refiner Exemption (SRE) can be a lot like that. It’s a little weird and a bit strange. In this month’s article, I am going to talk, somewhat briefly, about the “why” portion of SRE’s and, more importantly, what’s all the yelling about? As I’ve discussed in a previous article, to receive a small refiner exemption, you had to be a small refiner and you... Read More →

Becoming the Outcast: The “What” Portion of the Small Refiner Exemption

August 19, 2020

What do car wrecks, hangnails, and Small Refinery Exemptions (SRE) have in common? Nobody likes them. Well, ok, if you’re a participant in the Renewable Fuel Standard (RFS) and not a small refinery, you might not like SREs very much. But why, though? If you’re new to the RFS and you don’t have a good grasp of the industry, you might find all the hulabaloo a bit much. There is a lot that could be said about SREs, but for the moment, let’s discuss what they are first. There are two pieces to SRE’s. For the first piece, to even... Read More →

Save Your Receipts! The Inside Scoop on Product Transfer Documents

July 15, 2020

Do you ever go into a store and completely forget your grocery list? You walk out with a 9-foot receipt and items that you probably didn’t need. Or is that just me? Anyway, that 9-foot receipt is basically what the renewable fuel industry would call a Product Transfer Document (PTD). It works a lot like a receipt for a RIN transaction, and it’s required by the regulations. #bonus. Unlike my shopping experiences, a PTD can fit on a single page. Convenient, right? Every PTD is required to contain the following information: The name and address of the transferor and transferee... Read More →

The Biofuels Trilogy: Renewable Volume Obligations, RINs and the Renewable Fuel Standard

May 13, 2020

All the good things come in threes: the Three Amigos, the Hunger Games trilogy, three-for-one specials. I’m sure there’s more but, you get the picture. When the Renewable Fuel Standard (RFS) mandated the requirement of obligated parties to fulfill their obligation by retiring RINs, it created a market where RINs can be bought and sold among RFS participants. Driving this market are the annually-set Renewable Volume Obligations (RVOs), which can increase an obligated party’s need for RINs. In case you have no idea what that means, an obligated party incurs an obligation from the type of business activity they perform.... Read More →

Easy Peezy Lemon Squeezy: The Ins and Outs of the Renewable Volume Obligation

May 13, 2020

After reading the title to this article, I suppose you’re expecting to see a lot of regulatory and legal hieroglyphics. Plot twist. I’m going to explain the regulatory purpose of the Renewable Volume Obligation (RVO) in a way that makes sense and can include you in the industry conversation like the cool kid you are. #trendworthy. So what is the RVO and why should you care? Overall, the Renewable Volume Obligation is the volume of renewable fuel, in gallons, that must be blended to produce transportation fuel. On an individual level, the RVO is the regulatory duty (obligation) an importer... Read More →

Elementary, Dear Watson: A Beginner’s Guide to the Renewable Fuel Standard

May 13, 2020

What the heck is a RIN? How does the Renewable Fuel Standard actually work? When I first started with RINAlliance, I remember thinking it sounded like having an imaginary friend: beneficial sure, but people looked at you funny when you talked about it. To this day, my parents aren’t sure what I do is real, but since I’m not living out of their basement, they’re fine with it. #millenialproblems. I only have two pages, so I have to dive right in. The Renewable Fuel Standard (RFS) was the grandchild of the much bigger and more well-known Clean Air Act from... Read More →