Three Main Concerns Emerge around EPA’s RFS Proposal

1. Availability of RINs: A looming shortage of the RIN bank.

86 Fed. Reg. at 72,454/3: “A bank of carryover RINs is extremely important in providing a liquid and well-functioning RIN market upon which success of the entire program depends, and in providing obligated parties compliance flexibility in the face of substantial uncertainties in the transportation fuel marketplace.” The agency later describes that reducing liquidity in the carryover RIN bank would lead to significant negative impacts on both the fuels market and ongoing implementation of the RFS program.

2. Achievability of the 2022 RVO: An unrealistic target based on the government’s own projections.

86 Fed. Reg. at 72,477/3: “The RFS program has had limited success in helping to increase the use of higher ethanol blends, and growth in the nationwide average gasoline ethanol concentration has virtually stagnated as the market reached the E10 blendwall…We do not anticipate that growth in the use of higher ethanol blends through 2022 will increase rapidly enough to result in significantly greater volumes of ethanol consumption in the U.S., even with the incentives created by the RFS program standards and other governmental efforts such as Department of Agriculture’s (USDA’s) Blender Infrastructure Program and Higher Blends Infrastructure Incentive Program.”

3. Ability to meet the mandate: Betting on advanced biofuel and foreign biofuel imports

With the comment period set to close on February 4, 2022, time is running out for the public to provide input on EPA’s proposal.

To join the refinery workers, organized labor leaders, small business owners, regional business advocacy groups and elected officials urging EPA to address these concerns and reform the RFS, click here to add your voice to the growing coalition asking EPA to revise its RFS proposal.

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A coalition of union workers, local gas station owners, small retailers, and independent American refiners fighting to fix EPA’s flawed Renewable Fuel Standard.

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Fueling American Jobs Coalition

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A coalition of union workers, local gas station owners, small retailers, and independent American refiners fighting to fix EPA’s flawed Renewable Fuel Standard.

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