In comments submitted today to the U.S. Environmental Protection Agency, the Renewable Fuels Association opposed a proposal to extend the deadlines for demonstrating compliance with the Renewable Fuel Standard for 2019 and 2020.
“This proposal is unnecessary, and the timelines are excessive,” wrote RFA President and CEO Geoff Cooper. “All that the extensions would do is to compound problems that the EPA itself created under the last administration: the massive and unjustified increase in small refinery exemptions and the failure to finalize the 2021 renewable volume obligations by the statutory deadline.”
Cooper pointed out that it is reasonable to assume refiners and other obligated parties were already preparing to meet the March 31 regulatory compliance deadline when the EPA’s proposal was issued in January. Those refiners that did not prepare for compliance should not be rewarded for their bad behavior, Cooper said.
He also noted that if compliance credits had been needed to meet RFS obligations, they could have been acquired at low cost. Referring to the proposed 2019 extension, he observed, “If refiners did not use a sufficient volume of biofuels at that time and did not own enough renewable identification numbers (RINs) to cover the differential, they could have bought RINs at historically low prices during most of the period since then. In fact, RIN prices were considerably lower in March 2020 than they are in March 2021.”
The RFA called on the EPA to reject the proposed extensions and re-establish integrity in its implementation of the RFS.