In Halloween Comments, IRFA Urges EPA to End RFS Tricks and Treats by Fully Reallocating Refinery Exemptions

 IRFA Calls on EPA to Investigate Discrepancies Between SRE Recipients’ Public Statements and Waiver Criteria 

Press Contact: Hannah Love

515-322-0435

 

WEST DES MOINES, IA – Today the Iowa Renewable Fuels Association (IRFA) submitted formal comments to the Environmental Protection Agency’s (EPA) supplemental proposed Renewable Fuels Standard (RFS) blending rule for 2026-2027. As part of that proposed rule, the EPA is evaluating whether to reallocate 100% or 50% of refinery exemptions granted for 2023 and 2024, as well as those anticipated for 2025.  

In its comments, IRFA strongly supported the EPA’s proposal to reallocate 100% of the 2023-2025 refinery exemptions (SREs) while cautioning that “reallocating the SREs means nothing without finalizing the robust RFS blending levels proposed by the Agency for 2026-2027. Combing these actions will be like giving the renewable fuels market a full-size candy bar on Halloween and not one of those mini versions.” 

Key points from IRFA’s comments include: 

Maintain and Finalize the Robust Blending Level (RVO) Proposal for 2026-2027 

“IRFA strongly supports and urges the EPA to adopt the proposed RFS blending levels in the final rule.” 

 

SREs Should Be Few and Fully Reallocated 

“IRFA still strongly believes that the best way for the EPA to maintain the integrity of the RFS, to provide market certainty, and to ensure farmers, renewable fuels producers, and obligated parties are treated fairly is to ensure the granted SREs are few and fully reallocated.” 

 

SRE Tricks Should Not be Rewarded with Treats 

“IRFA strongly echoes the Attorneys General request that EPA not reward these potential tricks with SRE treats, and for EPA to engage with the SEC and all relevant federal agencies to ensure no refiner is misleading either the Agency or public shareholders.” 

 

EPA Must Fully Reallocate 2023-2025 RFS Exemptions to Prevent Demand Destruction 

“IRFA urges the Agency to finalize the 2026-2027 RFS blending rule with the robust standard volumes as previously proposed combined with additional SRE reallocation volumes designed to account for 100% of the 2023-2025 SREs.” 

 

50% Reallocation Simply Does Not Make Logical Sense 

“IRFA feels strongly that to suggest – after RFS rules have been proposed – that some of the zombie RINs are needed for RIN flexibility is illogical and would be detrimental to farmers while providing a windfall to refiners.” 

 

Reallocation Over Two Years is Appropriate, but 100% Reallocation is Paramount 

“As illogical and unsupportable as it would be, if EPA ultimately determines that 100% reallocation over 2026-2027 is not possible, the agency should not undermine the RFS with 50% reallocation. Instead, in that scenario, IRFA urges the EPA to reallocate 100% of the 2023-2025 exemptions over four years.” 

 

In conclusion, IRFA stated: “By getting the RFS back on track with robust, market-moving RFS blend levels and fully reallocating the 2023-2025 SRE zombie RINs, EPA can take the first step to turn around a struggling farm economy while boosting consumer access to lower-cost, home-grown fuels, and taking another step toward American Energy Dominance.” 

 

To read IRFA’s full comments, click here.

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The Iowa Renewable Fuels Association represents the state’s liquid renewable fuels industry and works to foster its growth. Iowa is the nation’s leader in renewable fuels production with 42 ethanol refineries capable of producing 4.7 billion gallons annually – including 34 million gallons of annual cellulosic ethanol production capacity – and 10 biodiesel facilities with the capacity to produce 416 million gallons annually. For more information, visit the Iowa Renewable Fuels Association website at: www.IowaRFA.org