August 22

AUGUST 22, 2018: Submitted Comments on Proposed RFS 2019 Standards


“HollyFrontier requests that EPA take three specific actions: (1) further reduce the renewable volume obligation using the general waiver authority given the inadequate volume of domestically produced renewable fuel available to obligated parties; (2) implement Renewable Identification Number (RIN) market reforms to increase RIN liquidity and decrease RIN prices; and (3) continue granting small refinery disproportionate economic hardship exemptions as required by the Clean Air Act when circumstances demonstrate a disproportionate economic harm.”

Independent Oil Workers

“The facts to date show that domestic biofuel use will remain robust even when the standard is waived for parts of the industry.  These facts prove EPA can set a reasonable volumetric requirement that is below the blendwall without adversely impacting domestic ethanol or other biofuel consumption, much of which is economic without government support.”

International Brotherhood of Electrical Workers

“EPA's proposed increase in the RFS requirement over 2018 levels fails to recognize the blendwall and the uneven playing field among RFS obligated parties. It could result in upward pressure on RIN costs, which as we saw earlier this year with Philadelphia Energy Solutions (PES), would once again threaten highly skilled domestic refining industry jobs.

New Jersey 3rd District Delegation

“In the high RIN price environment of the last two years, RINs became the [Paulsboro, NJ] refinery’s most significant operating expense; rising above pay, benefits and energy costs. The refinery spent nearly $150 million from 2015 to 2017 on RINs. Returning to such a financial environment would be unsustainable and certainly threaten jobs in the region.

The EPA must act now to prevent anti-consumer manipulative practices and advance RIN market reforms in the final 2019 RVO, rather than wait to pursues measures addressing RIN market integrity in the future.”

Northwest Ohio Building Trades

“The Toledo Refining Company provides 15 percent of the entire state’s fuel and contributes 5.2 billion dollars in total direct and indirect economic benefit to Northwest Ohio.  [Our] interest in this issue can be narrowed to the maintenance of skilled jobs and protection of our local economy.  This threat to the Refinery and the people it employs would have a direct detrimental impact on [our] 15,000 skilled construction workers and our community at large.”

PBF Energy

“The 2019 proposed conventional biofuel volumes should be lowered to avoid severe economic harm. Recent experience indicates setting unreasonable volume targets does result in such harm, but does NOT appreciably do anything to overcome the challenges of the blendwall and advance the RFS program’s objectives.  In addition, EPA should lower advanced biofuels limits that are overly aggressive to better reflect accurate domestic production.  EPA should also include RIN trading reforms in the RVO as well as advance other changes to ensure RIN market liquidity and limit compliance costs.”

Toledo Regional Chamber of Commerce

“We are encouraged that EPA is taking comment on RIN market reforms, but believe such reforms should be dealt with in the final RVO and not via a separate rulemaking. Even biofuel interests have questioned the volatility of the RIN market. The history of the program shows wild swings in RIN costs, but the percentage of ethanol blended into gasoline has stayed at around 10 cents regardless of whether RINs are three cents or $1.40."

United Steelworkers

“The reduced availability of additional biofuels to blend into the system creates logistical and technological challenges commonly known as the “blend-wall”. This has led to significant cost impacts for refineries as compliance costs related to Renewable Identification Number (RIN’s) pricing, which has wildly fluctuated based off of no logical demand structure, creates uncertainty for refineries and undermines long term investment strategies for domestic refining.  USW encourages the EPA to develop realistic biofuel assumptions that recognize the significant changes in fuels policy and the continued inability of commercially viable cellulosic biofuel to enter the market.”

United Way of Gloucester County

“The United Way of Gloucester County is genuinely indebted to the Paulsboro Refinery, whose philanthropy has empowered and strengthened the lives of Gloucester County residents over the years. If RIN costs were to skyrocket, our entire county would be negatively impacted. It would not only have a detrimental effect on the lives of the refinery employees; it would also heavily impact United Way’s funded programs and the local community.”

Valero Energy Corporation

“Since 2013, the RFS program has been fraught with challenges, yet EPA has set annual mandates every year at aspirational levels. In that time, EPA has made decisions based on interpretations of the statute that conflict with the goals and the structure of the statute.

Valero is concerned that EPA has yet again proposed RVOs that are not reasonably attainable and EPA has declined to make use of available authorities to reduce harms caused by the program and the volatile RIN market. In addition to our concerns about the volumes, corrections to the RFS [would] substantially improve the program and ensure that it continues to meet the statutory goals set by Congress: to support growth in renewable fuels in the U.S. and to enhance U.S. energy security and independence.”


Green Plains Inc.

August 1, 2018: Q2 2018 Results Earnings Call

Green Plains produced 296 million gallons of ethanol in the second quarter versus 275 million gallons for the same period in 2017. That was 80% of our operating capacity for the quarter. Ethanol production ran slower in the second quarter which is now going to be a thing of the past.”

–Todd Becker, President and CEO, Green Plains Inc.


Archer Daniels Midland Co.

July 31, 2018: Q2 2018 Results Earnings Call

“What’s interesting is on the demand side for domestic ethanol, we’re going to have some marginal improvements just due to the fact that gasoline consumption will go up a little bit.  U.S. economy is strong.  So you’re going to see some marginal growth in domestic demand.”

–Ray Young, Executive Vice President and CFO, Archer Daniels Midland Company


U.S. House Energy and Commerce Subcommittee on the Environment

July 25, 2018: Oversight Hearing on “Examining Renewable Identification Numbers under the Renewable Fuel Standard”

“Currently, the low RIN prices are the result of record domestic ethanol production and consumption, and this abnormally high RIN bank.”

–Corey Lavinsky, Director of Global Biofuels, S&P Global Platts

“The small refiner waivers are granted retrospectively, so the compliance year has already passed, but every refiner assumes they’re going to be an obligated party during that year. They will continue to blend renewable fuels and buy RINs as needed because they don’t know that they’re going to get the exemption at the twelfth hour when they go to report to the EPA by March 31st of the following year…

“Does it destruct the demand of the current year?  If you look at the RIN data through June, we’re at the same production level that we were in 2017 and we’re halfway towards meeting the 2018 compliance RVOs.

Sandra Dunphy, Director, Energy Compliance Services, Weaver and Tidwell, L.L.P.