Letters and Comments

Senate Letter to EPA on 2021 RVO

United States Senate

October 21, 2020 - Dear Administrator Wheeler, We write to urge you to use your authorities under the Clean Air Act (CAA) to ensure obligations imposed on refineries under the Renewable Fuel Standard (RFS) provide regulatory certainty for 2021, do not exceed the "blend wall" of ethanol's proportion of actually marketable fuel blends...Read the Full Letter

September 28, 2020 - “This week the Trump EPA made the decision to deny gap year small refinery exemption (SRE) waivers, combined with the agency’s refusal to appeal the 10th Circuit decision earlier this year on SRE waivers, essentially killing the SRE provisions of the EPA’s Renewable Fuel Standards (RFS) program. “While President Trump campaigns that he is a friend to energy workers, his administration’s policy decisions on the RFS program are hurting our members in refining and will not have the positive impact on farming he is promising. His decisions simply do not match his rhetoric...Real the Full Statement

Small Refinery CEOs Urge President to Protect Workers

American Refining Group, Par Hawaii Refining, Big West Oil, Placid Refining Company, Calumet Montana Refining, Sinclair Casper Refining, Continental Refining Company, San Joaquin Refining Co., Ergon Refining, Inc., United Refining Company and Countrymark Refining and Logistics

August 24, 2020 - Dear Mr. President: In Iowa last week you indicated that you would speak with EPA about the pending petitions for small refinery hardship relief under the Renewable Fuel Standard (RFS). In doing so, we urge you not to abandon your commitment to small refineries and to the employees and the rural communities that we serve. Instead, we ask that you resist efforts to harm the critical energy infrastructure you have fought so hard to protect during your Presidency under the false premise that doing so will help farmers...Read the Full Letter

NWF JOINS GOVERNORS CALLING FOR RFS WAIVERS

National Wildlife Federation

May 29, 2020 - Dear Administrator Wheeler: As of April 15, 2020, the U.S. Environmental Protection Agency (“EPA”) had before it waivers to the renewable volume obligation (“RVO”) of the federal Renewable Fuel Standard (“RFS”), requested by the Governors of Louisiana, Oklahoma, Pennsylvania, Texas, Utah, and Wyoming. These waiver requests are based upon a demonstration of “severe economic harm” as referenced in Section 211(o)(7) of the Clean Air Act (“the Act”)...Read the Full Letter

May 19, 2020 - Dear Administrator Wheeler: We write to urge you to use your authority under the Clean Air Act to waive or significantly reduce the renewable fuel volume obligations (RVOs) on America’s refineries for the 2020 compliance year. Since March, the United States has experienced an unprecedented drop in the demand for gasoline, diesel, and jet fuel. At the same time, the cost of complying with the Renewable Fuel Standard (RFS) has nearly tripled since January 2, 2020...Read the Full Letter

U.S. Attorney Generals' Letter to EPA Re RFS Waiver Requests

Office of Attorney General Jeff Landry (LA)

May 15, 2020 - Dear Administrator Wheeler: We write supporting the requests of several governors to waive the renewable fuel program requirements in section 211(o)(2) of the Clean Air Act. Waiving these requirements in times of severe market distress, especially those brought about by a global pandemic, is clearly justified by law and circumstance...Read the Full Letter

TX, LA, OK, UT, WY Delegation Letter to EPA

Congress of the United States

May 11, 2020 - Dear Administrator Wheeler: As members of the Texas, Louisiana, Oklahoma, Utah, and Wyoming delegations to Congress, we are writing you today to respectfully encourage the U.S. Environmental Protection Agency to quickly review requests made by our states to reduce the renewable volume obligation (RVO) under the Renewable Fuel Standard (RFS)...Read the Full Letter

May 11, 2020 - I write to reiterate my request of November 2, 2018, that you exercise the waiver authority in Clean Air Act Section 211(o)(7)(A)(i) to reduce the nationwide Renewable Fuel Standard (“RFS”) volume mandates to provide relief to refiners in Pennsylvania and elsewhere that are struggling to remain operational given the current and proposed volume requirements. The statutory deadline for a response to my petition passed almost fourteen months ago, and, in the interim, EPA has finalized both 2019 and 2020 RFS volume requirements that further underscore the urgent need for a severe-economic-harm waiver...Read the Full Letter

April 28, 2020 - Dear Administrator Wheeler, I’m pleased to hear that EPA is considering a temporary waiver of the Renewable Fuel Standard (RFS) ethanol blending mandate in response to the devastating impact of COVID-19 on global oil markets. Eliminating these burdensome mandates during this time of crisis is necessary if the Nation intends to retain its energy independence moving forward. Beyond the immediate benefits for the energy industry and its workers, this action would lower consumer food prices at a time when millions of Americans are suffering from severe financial hardship...Read the Full Letter

April 28, 2020 - Dear Mr. President: We write in strong support of the swift action your administration has taken in order to remove unnecessary barriers and red tape to improve COVID-19 response and economic recovery. The pandemic has underscored the need for permanent regulatory reform in a variety of areas, and we agree that work to expand prosperity on behalf of the American people must continue. 1 One area that warrants immediate attention is the Renewable Fuel Standard (RFS)...Read the Full Letter

Mayor of Oregon Requests RFS Waiver

Mayor Mike Sefarian (Oregon, OH)

April 22, 2020 - Dear Administrator Wheeler: On behalf of our City of Oregon, and in light of circumstances facing our state and the nation as a whole due to the COVID-19 epidemic, I write requesting you use your authority to immediately waive the renewable volume obligation (RVO) under the Renewable Fuel Standard (RFS) as authorized...Read the Full Letter

Mayor of Toledo Requests RFS Waiver

Mayor Wade Kapszukiewicz (Toledo, OH)

April 22, 2020 - Dear Administrator Wheeler: On behalf of our City of Toledo, and in light of economic circumstances facing our state and the nation as a whole due to the COVID-19 epidemic, I write requesting you use your authority to immediately waive the renewable volume obligation (RVO) under the Renewable Fuel Standard (RFS) as authorized...Read the Full Letter

April 16, 2020 - The Domestic Energy Producers Alliance (DEPA) supports the request made by the Governors of Texas, Utah, Oklahoma, Louisiana and Wyoming formally asking U.S. Environmental Protection Agency Administrator Andrew Wheeler for an expedited waiver of the renewable volume obligation (RVO)* under the Renewable Fuel Standard RFS consistent with Section 211(o)(7) of CAA in order to address severe economic harm compounded by the current national emergency...Read the Full Press Release

GOVERNORS TO EPA: WAIVE RFS OBLIGATIONS

Governor Abbott (TX), Governor Herbert (UT), Governor Stitt (OK) and Governor Gordon (WY)

April 15, 2020 - Dear Administrator Wheeler: On behalf of our States, and in light of economic circumstances facing our States and the Nation as a whole, please expedite this request for a waiver of the renewable volume obligation (RVO) under the federal Renewable Fuel Standard (RFS) as authorized under Section 211(o)(7) of the Clean Air Act (CAA)(42 U.S.C. §7545(o)(7)) as amended by the Energy Independence and Security Act of 2007. Under this waiver provision...Read the Full Letter

Governor Edwards Calls for Expedited RFS Waiver

Office of Governor John Bel Edwards (LA)

April 7, 2020 - Dear Administrator Wheeler: On behalf of our States, and in light of economic circumstances facing our States and the Nation as a whole, please expedite this request for a waiver of the renewable volume obligation  (RVO) under the federal Renewable Fuel Standard (RFS)...Read the Full Letter

March 22, 2020 - Dear Administrator Wheeler: As members of the Texas Delegation to Congress, we are writing to strongly encourage the U.S. Environmental Protection Agency (EPA) to continue to press the case for regulatory relief available to small refinieres...Read the Full Letter

March 6, 2020 - U.S. Sens. Ted Cruz (R-Texas), Mike Enzi (R-Wyo.), John Barrasso (R-Wyo.), Jim Inhofe (R-Okla.), Pat Toomey (R-Penn.), John Kennedy (R-La.), Mike Lee (R-Utah), Bill Cassidy (R-La.), Shelley Moore Capito (R-W.V.), and James Lankford (R-Okla.) today issued a statement following reports that President Trump will appeal the Tenth Circuit’s decision on small refineries: “We’re encouraged by the reports that the administration will appeal the Tenth Circuit’s decision on small refineries,” the senators said...Read the Full Statement

Gov. Herbert's Energy Advisor Supports RFS Decision Review

Office of Governor Gary Herbert (UT)

March 5, 2020 - Dear Mr. President: Utah is consistently recognized for its top-rated economy and high quality of life. Utah’s forward-looking, market based energy policy, which your administration has championed, is at the heart of Utah’s successful formula. Utah appreciates your commitment to supporting sufficient state flexibility under the EPA’s Renewable Fuels Standard (RFS) program to remain economically viable while also achieving environmental goals through innovative and effective solutions tailored to local needs...Read the Full Letter

March 3, 2020 - Dear Mr. President: We write to you regarding the neccessary preservation of small refinery exemptions ("SREs") under the Clean Air Act. It has been reported that the U.S. Environmental Protection Agency ("EPA") will apply the Tenth Circuit's holding in Renewable Fuels Association, et al. v. EPA nationwide. We respectfully ask that you reconsider this decision, as it will jeopardize or otherwise end small refinery hardship relief and result in the loss of countless jobs of those Americans that contribute to the energy independence of the U.S. economy....Read the Full Letter

March 3, 2020 - Dear Administrator Wheeler: It is our understanding that the U.S. Environmental Protection Agency (EPA) may be considering changes to the small refinery exemptions (SREs) available under the Renewable Fuel Standard (RFS).  It is already our view that EPA' s decision to prospectively reallocate 770 million gallons in potential SREs in the 2020 renewable volume obligation (RVO) was imprudent and misguided.  Now, EPA would risk compounding this error by not issuing SREs equal to this amount, thereby massively increasing the burden placed on U.S. refineries...Read the Full Letter

Governor Stitt to Wheeler Re 10th Circuit Appeals Decision

Office of Governor J. Kevin Stitt (OK)

March 2, 2020 - Administrator Wheeler: I am writing you to express my concern about the recent decision from the U.S. 10th Circuit Court of Appeals which ended the small refinery exemption ("SRE") under the federal Renewable Fuel Standard. This is of great concern to me as several entities that are vital to Oklahoma's economy...Read the Full Letter

Mayor of Cheyenne, WY to Trump Re RFS Concerns

Office of Mayor Marian Orr (Cheyenne, WY)

February 29, 2020 - Dear President Trump: As mayor of Cheyenne, Wyoming, I write today to express my concern that the Environmental Protection Agency is being pressured to eliminate the relief program that exists to help small refineries avoid severe economic hardship from the Renewable Fuel Standard (RFS). It is being discussed that the EPA is going to give up their right to appeal a court ruling that undermines the RFS relief program and thereby apply this court’s ruling to the entire country. I respectfully ask for your intervention by not allowing them to do so....Read the Full Letter

Gov. Gordon to Trump Re 10th Circuit Decision

Office of Governor Mark Gordon (WY)

February 28, 2020 - Dear President Trump: I write concerning media reports that the Administration is exploring changes to the Renewable Fuel Standard (RFS) program due to a recent decision by a three-judge panel of the U.S. Court of Appeals for the Tenth Circuit. Wyoming is home to five refineries that are disproportionately harmed by the RFS...Read the Full Letter

Senators Call on President Trump to Fight for Small Refineries

U.S. Senate Committee on Environment & Public Works

February 27, 2020 - Today, U.S. Senator John Barrasso (R-WY), chairman of the Senate Committee on Environment and Public Works (EPW), along with a dozen other senators, sent a letter to President Trump urging him to file a petition for a rehearing of the U.S. Court of Appeals for the Tenth Circuit’s decision to invalidate hardship relief for small refineries under the Renewable Fuel Standard (RFS)...Read the Full Letter

Sen. Barrasso Letter to EPA Opposing Recent RFS Proposal

U.S. Senate Committee on Environment & Public Works

December 2, 2019 - U.S. Senator John Barrasso (R-WY), chairman of the Senate Committee on Environment and Public Works (EPW), sent a letter to Environmental Protection Agency (EPA) Administrator Andrew Wheeler to express his opposition to the agency’s recent proposal regarding the Renewable Fuel Standard (RFS). EPA recently proposed to reallocate the blending obligations of small refineries, which receive hardship relief under the RFS, to refineries (small and large), which do not receive or are ineligible for hardship relief...Read the Full Letter

Valero RVO Supplemental 2020 Comments

Valero Energy Corporation

November 29, 2019 - The Valero Energy Corporation and its subsidiaries (collectively, “Valero”) submit these comments on EPA’s Supplemental Notice of Proposed Rulemaking for the Renewable Fuel Standard Program: Standards for 2020 and Biomass-Based Diesel Volume for 2021, and Response to the Remand of the 2016 Standards. Valero’s unique position as a refiner, importer, exporter, marketer and renewable diesel and ethanol producer means that Valero views the RFS program from several perspectives that can be helpful to EPA in evaluating and considering issues in the RFS program...Read the Full Letter

November 29, 2019 - PBF Holding Company LLC, a subsidiary of PBF Energy Inc. (“PBF”), respectfully submits these comments in response to the Environmental Protection Agency’s (EPA’s) “Renewable Fuel Standard Program: Standards for 2020 and Biomass-Based Diesel Volume for 2021, and Response to the Remand of the 2016 Standards; Supplemental Notice of Proposed Rulemaking” (EPA-HQ-OAR-2019-0136;FRL– 10001–36–OAR) (the “proposed supplemental RVO” or “proposed supplemental”). PBF is a member of and acknowledges the comments submitted by the American Fuel & Petrochemical Manufacturers (AFPM) (the “AFPM comment letter”)...Read the Full Letter

AFPM 2020 RFS Supplemental NPRM Comments

American Fuel & Petrochemical Manufacturers

November 29, 2019 - The American Fuel & Petrochemical Manufacturers (“AFPM”) submits these comments in response to the Environmental Protection Agency’s (“EPA” or “Agency”) Supplemental Notice of Proposed Rulemaking (“Supplemental Proposal”) referenced above.1 AFPM’s members operate approximately 110 refineries - accounting for more than 95 percent of U.S. refining capacity - that produce the gasoline, diesel, jet fuel, and petrochemical building blocks for thousands of products that make innovation and progress possible...Read the Full Letter

November 27, 2019 - Monroe Energy, LLC (“Monroe”) respectfully submits these comments on EPA’s Supplemental Notice of Proposed Rulemaking (“Supplemental Notice”) with respect to the Renewable Fuel Standard (“RFS”) program for 2020. Monroe owns a refinery in southeastern Pennsylvania and is an obligated party under the RFS program...Read the Full Letter

November 27, 2019 - These comments are submitted on behalf of the 850,000 members of the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union (“United Steelworkers” or “USW”). The USW represents working people across multiple sectors, including approximately two thirds of domestic petroleum refining, accounting for 30,000 well-paying, community supporting jobs at over 75 locations across the country, and also represents workers in the biofuel industry at ethanol facilities...Read the Full Letter

November 26, 2019 - HollyFrontier Corporation (“HollyFrontier”) is pleased to provide the following comments on Environmental Protection Agency’s (“EPA”) Supplemental Notice of Proposed Rulemaking, “Renewable Fuel Standard Program: Standards for 2020 and Biomass-Based Diesel Volume for 2021, and Response to the Remand of the 2016 Standards” (“Supplemental Notice”) Docket No. EPA-HQ-OAR-2019-0136-0021. 84 Fed. Reg. 57,677 (October 29, 2019). As detailed below, HollyFrontier opposes upward adjustments of the 2020 standards based on estimated projections of the volume of gasoline and diesel that will be exempt in 2020 due to small refinery exemptions...Read the Full Letter

November 26, 2019 - We are concerned by the recent actions of the U.S. Environmental Protection Agency (EPA) that seem to undermine the regulatory relief required under the Clean Air Act (the Act) and the promises by President Trump to protect refinery jobs in light of the potentially adverse effects of the Renewable Fuel Standard (RFS). Your October 15, 2019, Proposed Volumes for 2020 and Biomass-Based Diesel Volume for 2021: Supplemental Notice...Read the Full Letter

Los Angeles/Orange Counties Building Trades Statement on "Protecting the RFS" House Hearing

Los Angeles/Orange Counties Building and Construction Trades Council

October 28, 2019 - On behalf of the Los Angeles/Orange Counties Building and Construction Trades Council and the more than 100,000 skilled men and women it represents, I am writing to express deep concern regarding the House Energy & Commerce Committee Environment & Climate Change Subcommittee's upcoming hearing entitled, "Protecting the RFS: The Trump Administration's Abuse of Secret Waivers," will only served to attack elements of the Renewable Fuel Standard (RFS) program that...Read the Full Statement

October 28, 2019 - On behalf of the 850,000 members of the United Steelworkers (USW), our union submits the following comments to the Subcommittee on the Environment and Climate Change regarding the October 29th hearing on "Protecting the RFS: The Trump Administration's Abuse of Secret Waivers." While the subject of transparency in the Renewable Fuel Standard (RFS) is important, our union is concerned about the limited scope of this hearing...Read the Full Statement

October 4, 2019 - U.S. Sen. Ted Cruz (R-Texas) today issued a statement following the administration’s announcement rolling back regulatory relief for independent and small refineries: “I am disappointed that the administration intends to roll back the regulatory relief President Trump recently provided to our nation’s independent refineries...Read the Full Statement

Sen. Barrasso: New Biofuel Mandates will Do More Harm than Good

U.S. Senate Committee on Environment & Public Works

October 4, 2019 - Today, Senator John Barrasso (R-WY), chairman of the Senate Committee on Environment and Public Works (EPW), issued the following statement in response to the administration announcing a series of steps to change biofuel mandates under the Renewable Fuel Standard (RFS)...Read the Full Statement

September 24, 2019 - On behalf of the Petroleum Alliance of Oklahoma and our 1,300 member companies representing tens of thousands Oklahoma families who work in the oil and natural gas industry, I write to share our concerns with the misguided proposals some within your administration are advocating for related to Renewable Fuel Standard (RFS) hardship waivers granted by the EPA...Read the Full Letter

September 24, 2019 - I am writing you today on behalf of the New Mexico Oil & Gas Association, (NMOGA) a coalition of more than 1,000 oil and natural gas comapnies operating in New Mexico. The oil and gas industry supports over 100,000 jobs in New Mexico, the majority of which are in communities that align with your America First energy policies...Read the Full Letter

September 24, 2019 - Today, the Institute for Energy Research (IER) announced it has filed a second open records request with the U.S. Department of Agriculture (USDA) to compel the release of certain documents under the Freedom of Information Act (FOIA) related to the agency’s involvement in the Renewable Fuel Standard (RFS) regulatory process...Read the Full Statement

September 23, 2019 - The American Fuel & Petrochemical Manufacturers (“AFPM”) submits these comments in response to the Environmental Protection Agency’s (“EPA’s”) Section 610 Review of “Regulation of Fuels and Fuel Additives: Changes to Renewable Fuel Standard Program.” 1 AFPM is a national trade association whose members comprise virtually all United States refining and petrochemical manufacturing capacity. AFPM members are directly regulated as obligated parties under the Renewable Fuel Standard (“RFS”) and will be substantially affected by the outcome of EPA’s 610 Review...Read the Full Letter

September 23, 2019 - PBF Holding Company LLC, a subsidiary of PBF Energy Inc. (“PBF”), respectfully submits these comments in response to the Environmental Protection Agency’s (EPA’s) “Section 610 Review of the Renewable Fuel Standard Program” (EPA-HQ-OAR-2019-0168-0001) (“the review”). PBF is a member of and acknowledges the comments submitted by the American Fuel & Petrochemical Manufacturers (AFPM) (the “AFPM comment letter”). PBF’s comments are intended to complement and emphasize those raised in the AFPM comment letter. PBF’s comments addresses relevant issues from the unique perspective of its role as a merchant refiner...Read the Full Letter

Governor Herbert Letter to Trump Re RFS Refinery Relief

The Office of Governor Gary Herbert (R-UT)

September 16, 2019 - Utah is consistently recognized for its vibrant economy and high quality of life. Like you, I recognize the important role of energy in dirving economic opportunities. I also appreciate your administration's support of state leadership to advance smart, market-based solutions to meet local challenges...Read the Full Letter

September 12, 2019 - We are proud to be refinery managers, responsible for safely manufacturing the gasoline, diesel, jet fuel, heating oil, and other products that keep the U.S. economy moving and that serve as the foundational elements of modern life. Our refineries are the lifeblood of the communities that we call home...Read the Full Letter

September 12, 2019 - The undersigned write to object to several of the proposals under consideration regarding the Renewable Fuel Standard (RFS). It is time for the special favors for the ethanol industry to end. The EPA has already illegally allowed E15 fuels to benefit from a year-round waiver from generally applicable clean air regulations, despite statute clearly granting such a waiver only to E10 blends...Read the Full Letter

September 12, 2019 - We write today to thank you for your work to ensure small refineries are not harmed by the Renewable Fuel Standard (RFS) mandate and express concern that your administration is considering actions that would undermine this good work. Any reallocation of volumes from statutory...Read the Full Letter

September 7, 2019 - On behalf of the 18,000 members of the Delaware County Labor Council, I'm writing to express concern regarding recent press reports which could threaten the manufacturing jobs you promised to protect. Our Labor Council...Read the Full Letter

September 6, 2019 - On behalf of the 1.2 million active and retired members of the United Steelworkers, I write to express concern regarding the Renewable Fuel Standard (RFS) and recent reports of possible Administrative action to the RFS. As the largest union in the refining sector, representing roughly two-thirds of domestic refining capacity, we are concerned about potential impacts to small refineries and the threat to union jobs in multiple states...Read the Full Letter

September 6, 2019 - We are writing in regards to the importance of Small Refinery Exemptions (SREs), which are issued by the Environmental Protection Agency (EPA) to qualifying refineries with less than 75,000 barrels pery day throughput. When Congress...Read the Full Letter

Letter on Small Refinery Hardship Relief Under the RFS

LeAnn Johnson Koch, Perkins Cole LLP

September 3, 2019 - I am writing on behalf of a coalition of small refinery owners to share their appreciation for your administration’s decision to protect critical energy infrastructure and many thousands of stable and high-paying manufacturing jobs by granting small refinery hardship relief under the Renewable Fuel Standard (RFS)...Read the Full Letter

Chairman Barrasso Responds to Reports of New Biofuel Mandates

U.S. Senate Committee on Environment and Public Works

September 3, 2019 - Today, Senator John Barrasso (R-WY), chairman of the Senate Committee on Environment and Public Works (EPW), issued the following statement in response to reports the administration plans to unveil a series of steps to change biofuel mandates under the Renewable Fuel Standard (RFS)...Read the Full Statement

August 30, 2019 - PBF Holding Company LLC, a subsidiary of PBF Energy Inc. (“PBF”), respectfully submits these comments in response to the Environmental Protection Agency’s (EPA’s) “Renewable Fuel Standard Program: Standards for 2020 and Biomass-Based Diesel Volume for 2021, Response to the Remand of the 2016 Standards, and Other Changes,” (EPA–HQ–OAR–2019–0136; FRL–9996–53–OAR) (the “proposed RVO”)...Read the Full Statement

August 30, 2019 - The Valero Energy Corporation and its subsidiaries (collectively, “Valero”) submit these comments on EPA’s proposed rule Renewable Fuel Standard Program: Standards for 2020 and Biomass-Based Diesel Volume for 2021, Response to the Remand of the 2016 Standards, and Other Changes. Valero’s unique position as a refiner, importer, exporter, marketer and biodiesel and ethanol producer means that Valero views the RFS program from several perspectives that can be helpful to EPA in evaluating and considering issues in the RFS program...Read the Full Statement

August 30, 2019 - The International Brotherhood of Boilermakers represents American workers in industrial construction, repair, and maintenance, including in many of our nation's refineries. Our members are highly skilled...Read the Full Letter

August 30, 2019 - HollyFrontier Corporation is an independent petroleum refiner that produces high-value light products such as gasoline, diesel fuel, jet fuel, specialty lubricant products and specialty and modified asphalt. HollyFrontier also operates...Read the Full Letter

August 30, 2019 - On behalf of the 355,000 members of the United Association of the Plumbing and Pipefitting  Industry  of  the United  States and  Canada  (UA), I write  regarding my  continued  concern with  the  renewable  fuel  standard  and  the  small  refinery  exemptions  that  your  administration  has  successfully implemented.       We  are  writing  to  emphasize  that  we  are  in  complete  agreement  with  the  attached  letter  from  the  American  Fuel  &  Petrochemical  Manufacturers  (AFPM)  and  the  American  Petroleum  Institute  (API).    The  facts  are  clear  that  there  has  been  NO  reduction  in  biofuel  consumption  associated with the Small Refinery Exemptions (SREs)...Read the Full Letter

Ethanol Producers Letter to President Trump

Valero Energy Corporation, Marathon Petroleum Corporation, Flint Hills Resources

August 28, 2019 - As some of the nation's largest ethanol producers, we write today to thank you for your continued support of the entire U.S. liquid fuels industry. Collectively, our companies produce nearly 20 percent of the current U.S. ethanol supply...Read the Full Letter

AFPM & API Letter to the President

American Fuel and Petrochemical Manufacturers & American Petroleum Institute

August 28, 2019 - On behalf of the American Fuel and Petrochemical Manufacturers (AFPM) and the American Petroleum Institute (API), we write to share our concerns with the misinformation and misguided proposals the ethanol industry and some within your administration are advocating for in the wake of recent Renewable Fuel Standard (RFS) hardship waivers (SREs) granted by EPA to certain small refineries. Frankly, these folks are attempting to...Real the Full Letter

Letter to President Trump Regarding SREs

North America's Building Trades Unions

August 22, 2019 - On behalf of the 3 million skilled craft professionals that constitute the 14 affiliates of North America’s Building Trades Unions (NABTU), I am writing in support of your Administration’s recent actions to grant Small Refinery Exemptions (SREs) to the Renewable Fuel Standard (RFS), without increasing the mandate for other refiners. I also urge you to...Read the Full Letter

August 8, 2019 - On behalf of the State of Mississippi, I am writing regarding the importance of Small Refinery Hardship Exemptions (SREs) which are issued by the EPA to qualifying refineries with less than 75,000 barrels per day throughput. When congress enacted...Read the Full Letter

PA HOUSE MEMBERS TO PRESIDENT TRUMP: STAND BY PA ENERGY, SUPPORT SREs

Pennsylvania Members of the U.S. House of Representatives

July 26, 2019 - We write in support of well-paying energy sector jobs and energy security in Pennsylvania and the United States..Read the Full Letter

July 16, 2019 - I represent numerous small refinery owners, identified in Appendix A, who are awaiting overdue decisions on their 2018 petitions for small refinery hardship relief under the Renewable Fuel Standard (“RFS”)...Read the Full Letter

Letter From Governor Abbott of Texas Regarding RFS Program

The Office of Governor Greg Abbott (R-TX)

July 12, 2019 - On behalf of the State of Texas, and following up on my letter of December 1, 2017, I am again writing to the U.S. Environmental Protection Agency (EPA) regarding the renewable fuel standard (RFS) program established by the federal Clean Air Act, 42 U.S.C...Read the Full Letter

Small Refinery Letter to Administrator Wheeler

LeAnn Johnson Koch, Perkins Cole LLP

July 8, 2019 - Recent media reports indicate that the Secretary of Agriculture is attempting to gain access to the confidential business information (CBI) submitted by small refineries during the hardship petition process...Read the Full Letter

July 1, 2019 - Sens. Cruz, Barrasso, Inhofe, Toomey, Kennedy, Wicker, Lee, Enzi, Cassidy, Capito, Cornyn, Lankford, and Daines sent President Trump a letter asking him to prohibit the Secretary of Agriculture from influencing the decision making process when small refineries petition the EPA for relief from annual obligations due to economic hardship....Read the Full Letter

June 26, 2019-- Sens. Cruz, Barrasso, Inhofe, Toomey, Kennedy, Wicker, Lee, Enzi, Cassidy Urge Administration to Uphold the Rule of Law and Block Senate Democrats' Efforts to Roll Back President Trump's Energy Independence Accomplishments... Read the Full Letter

November 13, 2018 - On behalf of Monroe Energy, LLC, I hereby request that you exercise your waiver authority under 42 U.S.C. § 7545(o)(7)(A)(i) to reduce the 2018 and 2019 renewable fuel volume mandates because implementation of the Renewable Fuel Standard (“RFS”) program is causing severe harm to the economy of the Commonwealth of Pennsylvania and to the Petroleum Administration for Defense District (“PADD”) Region 1, in which Monroe operates. Monroe supports the separate waiver petition filed by the Commonwealth of Pennsylvania on November 2, 2017, and resubmitted on November 2, 2018...Read the Full Letter

Letter Sent By Pennsylvania Governor Tom Wolf for RFS Waiver

The Office of Governor Tom Wolf (D-PA)

November 2, 2018 -  By letter dated November 2, 2017, I petitioned EPA to exercise the waiver authority in Clean Air Act Section 211(o)(7)(A)(i) to reduce the nationwide renewable fuel volume mandate in order to address the economic difficulties faced by refiners in Pennsylvania and elsewhere in complying with this mandate. As I noted in that petition, the request was “based upon the high cost of compliance with the Renewable Fuel Standard (RFS) and the impacts these costs have on the continued viability of the oil refining sector in the Northeast, as well as on the local and regional economies.”... Read the Full Letter

October 4, 2018 - In recent months, media outlets reported that the Environmental Protection Agency (EPA) is considering regulatory action to expand the sale of gasoline with 15 percent ethanol by volume (E15) year-round by waiving certain Clean Air Act (CAA) requirements related to Reid Vapor Pressure (RVP)... Read the Full Letter 

September 14, 2018 - We write to you today as Members of Congress repesenting the Commonwealth of Pennsylvania who are concerned about the negative impact the renewable fuel standard (RFS) is having on our constituents and the state's economy... Read the Full Letter

September 13, 2018 - As the Trump Administration prioritizes regulatory reform, it is important that future modifications to the Renewable Fuel Standard (RFS) consider the economic impact to all sectors of the U.S. economy... Read the Full Letter

July 26, 2018 - In recent weeks, media reports indicated that the Enviornmental Protection Agency (EPA) considered a proposal to retroactively reallocate the Renewable Fuel Standard (RFS) compliance obligations from small refineries, which have recieved hardship relief, to other refineries and importers...Read the Full Letter 

July 25, 2018 - The United Steelworkers (USW) writes today urging Congress to follow through with proposed changes to the Environmental Protection Agency's (EPA) Renewable Fuel Standard (RFS) designed to reduce compliance costs for independent merchant oil refiners. The USW represents 850,000 men and women employed in metals, mining, pulp and paper, rubber, chemicals, glass, auto supply and the energy-producing industries, along with a growing number of workers in public sector and service occupations...Read the Full Letter

May 22, 2018 - On behalf of the International Brotherhood of Boilermakers, Iron Ship Builders, Blacksmiths, Forgers and Helpers, I write to express our strong support for reform of the renewable identification numbers (RINSs) program as a compliance mechanism for the EPA's renewable fuel standard (RFS)...Read the Full Letter

May 17, 2018- On behalf of the 345,000 members of the United Association of the Plumbing and Pipefitting Industry of the United States and Canada, I write again regarding my continuing concern with the Renewable Fuel Standard (RFS). However, today I write applauding news of your decision to advance a rule that would allow all Renewable Identification Numbers (RINs) associated with all exported biofuel to be used for RFS compliances... Read the Full Letter

May 10, 2018 - On behalf of the nearly 500 hardworking men and women of the Paulsboro Refinery, of which most are represented by the Independent Oil Workers (IOW), I would like to applaud you for agreeing a rule that will allow all RINs associated with all biofuel exports to be available for compliance...Read the Full Letter

March 12, 2018 - On behalf of more than 50,000 members of the International Brotherhood of Boilermakers, I write urging you to expeditiously act on sensible reforms to the federal Renewable Fuel Standard (RFS). The cost of the program's credits, called Renewable Identification Numbers (RINs), have skyrocketed in recent years. As a result, the largest refinery on the East Coast, owned by Philadelphia Energy Solutions (PES), was forced to declare bankruptcy....Read the Full Letter

January 30, 2018-  As Governor of the State of Delaware, please let this serve as my request that you exercise the waiver authority contained in Clean Air Act Section 211 (o)(7)(A)(i) to reduce the nationwide renewable fuel volume mandates in order to provide relief to the refiners in Delaware and elsewhere grappling with tremendous operational impediments due to the current and proposed volume mandates.... Read the Full Letter

January 25, 2018 - On behalf of the more than 343,000 members of the United Association of the Plumbing and Pipefitting Industry of the United States and Canada, I write regarding my continued concern with the Renewable Fuel Standard (RFS) created by the Energy Independence and Security Act of 2007 (EISA). Just one year ago, I wrote to EPA Administrator Scott Pruitt outlining how the structure...Read the Full Letter

December 1, 2017 - The escalating and unjustified RINs prices are creating a severe economic hardship for refiners, small retailers, consumers, skilled labor, and others. Texas companies directly suffer from spiked RNs prices. During previous RINs spikes, Texas merchant refiners lost as much as 64 percent of stock value.2 While it is true that some companies have made money off of expensive RINs, the majority of refiners are hurt by them. I am formally requesting an appropriate waiver of the renewable volume obligation under RFS consistent with Section 21 l(o)(7) of CAA and reasonable use of enforcement discretion in order to address implementation issues and stabilize the RINs market at relative concentrations closer to those originally anticipated by Congress and predicted by EPA at the outset of the program... Read the Full Letter

November 22, 2017 - Please accept this petition under section 211(o)(7)(A) of the Clean Air Act. Pursuant to this provision, you are authorized to avoid the risk of severe economic harm to a state, a region, or the entire Nation arising from the requirements imposed by the renewable fuel standard ("RFS")... Read the Full Letter 

November 14, 2017 - As you know, I, along with eight other Senators representing states whose constituents depend on a strong and robust refining industry, recently requested that President Trump convene a meeting with us and our colleagues representing various Midwest states, to discuss elements of the Renewable Fuel Standard (RFS). Our goal in requesting this meeting is simple; to bring together diverse interests in an effort to come together and find a mutually beneficial outcome that will help both Iowa corn growers as well as protect blue-collar, refinery jobs that are at risk in too many states across our great nation... Read the Full Letter

November 7, 2017 - We write today with concerns about possible market manipulation in the compliance trading system used for the Environmental Protection Agency (EPA)'s Renewable Fuel Standard (RFS) program, known as the Renewable Identification Number (RIN) market. We believe RIN market manipulation - and the resulting market volatility - is negatively affecting the economic stability of East Coast refineries. We ask that your agency investigate and end any possible RIN market manipulation under the jurisdiction of the Federal Trade Commission's Petroleum Market Manipulation Rule.... Read the Full Letter

October 25, 2017 - If your administration does not make adjustments or reforms on matters related to the Renewable Fuel Standard (RFS), it will result in a loss of jobs around the country, particularly in our states. We request that within the next three weeks you convene a meeting regarding the RFS and pro-jobs policies with us, our Senate colleagues who previously lobbied you on behalf of the ethanol industry, and relevant members of your administration, to discuss a pathway forward toward a mutually agreeable solution that will also save refining jobs and help unleash an American energy renaissance... Read the Full Letter

October 20, 2017 - I write to ask your assistance in protecting hundreds of good paying energy sector jobs in Philadelphia and the surrounding area. Specifically I bring to your concern that the high cost of compliance with the Renewable Fuel Standard (RFS) Renewable Identification Number (RIN) credit is undermining the continued viability of the oil refining sector in the northeast. I would like to work with your Administration to develop a path forward that lowers the compliance costs and protects these good paying, familiy sustaining jobs... Read the Full Letter

Letter that the CEO's of Four Refineries sent to President Trump

Valero Energy, PBF Energy, HollyFrontier & Monroe Energy

October 18, 2017 - We strongly support your administration's recent review of the Renewable Fuel Standard (RFS). Specifically, recent media reports suggest your EPA may be considering a policy to treat exported gallons of biofuel the same as domestically consumed biofuel under the RFS program. Doing so would not only bolster the golas of the RFS and boost domestic renewable fuels production, but also provide much-needed regualtory relief for merchant refiners... Read the Full Letter

October 18, 2017 - On behalf of the 850,000 members of the United Steelworkers (USW), I am writing to express our support for lowering the Renewable Fuel Standard (RFS) final biomass-based diesel requirement for 2018, as well as making reductions from the proposed 2019 standard. I also write to support a proposal allowing RFS credits, called Renewable Identification Numbers (RINs), associated with exported ethanol to be used for RFS compliance...Read the Full Letter

October 6, 2017 - We write to ask your assistance in supporting thousands of well-paying energy sector jobs in Phildelphia and the surrounding area. Specifically, we are concerned that the high cost of compliance with the Renewable Fuel Standar (RFS) through the submission of Renewable Identification Number (RIN) credits is undermining the continued viability of the oil refining sector in the Northeast. We ask that your administration address RINs in an effort to reduce compliance costs and support thousands of well-paying jobs in Pennsylvania's energy sector... Read the Full Letter

August 30, 2017 - As the President of the USW Local 10-234 representing over 200 union brothers and sisters at Monroe Energy’s refinery in Trainer Pennsylvania, I’m writing to you because we need your help. We support Monroe Energy’s comments on the proposed RFS Program Standards for 2018, and Biomass-Based Diesel Volumes for 2019 to change the point of obligation under the Renewable Fuel Standard (RFS), lower volume requirements, and institute RIN market fixes to reduce the cost of RINs....Read the Full Letter

August 1, 2017- My name is Suzanne Murray and I am making a statement on behalf of Mr. Karim Dhukani and other minority business owners from the Small Retailers Coalition. Mr. Dhukani is the owner of Express Fuel Products in Houston, Texas... Read the Full Statement 

August 1, 2017- Good Morning! My name is Bill Douglass and I chair the” Small Retailer Coalition”. Our family has a Petroleum Distributorship in North Texas, which also operates 22 Convenience stores with fuel... Read the Full Statement 

July 6, 2017- On behalf of the 850,000 members of the United Steelworkers (USW), I wish to express our deep concern and opposition to S. 517 the Consumer and Fuel Retailer Choice Act as currently drafted... Read the Full Statement 

February 22, 2017 - I am Mark McManus, General President of the United Association of Plumbers, Steamfitters and Pipefitters for the United States and Canada. A large percentage of our 340,000 members work in the domestic refining industry across the U.S., building, maintaining, and servicing these highly complex facilities on a daily basis. The United Association, in conjunction with North America's Building & Construction Trades Union, has a well-established presence in many of these refineries, in some cases for more than 100 years...Read the Full Letter

February 19, 2017 - As the President of the USW Local 10-234 representing over 200 union brothers and sisters at Monroe Energy’s refinery in Trainer, Pennsylvania, I write today urging you to grant Monroe Energy’s Petition for Rulemaking to change the point of obligation under the Renewable Fuels Standard (RFS). Monroe and other merchant refiners in the Philadelphia region are under immense financial pressure because of the imbalanced nature of the RFS program. Reform is needed now, before it’s too late for our refineries...Read the Full Letter

February 15, 2017 - As the Business Manager of the Steamfitters Local Union 420 which represents 4600 skilled craftsmen, I write today urging you to grant Monroe Energy's Petition for Rulemaking to change the point of obligation under the Renewable Fuel Standard (RFS). Monroe and other merchant refiners in the Philadelphia region are under immense financial pressures...Read the Full Letter