In detailed comments submitted today to the U.S. Environmental Protection Agency, the Renewable Fuels Association expressed strong support for EPA’s proposed Renewable Fuel Standard volumes for 2026 and 2027, while also recommending slight modifications to the agency’s plan for prioritizing American-made renewable fuels over import-based fuels.
“We strongly support EPA’s proposed RVOs and, specifically, the implied conventional renewable fuel volumes of 15 billion gallons for both 2026 and 2027,” wrote RFA President and CEO Geoff Cooper. “This will provide the ethanol industry with room for growth as gasoline blends containing 15 percent ethanol (E15) continue to gain momentum in the marketplace. Expanding the use of domestically produced renewable fuels like ethanol is key to achieving President Trump’s vision for lower fuel prices, a stronger agriculture industry, and American energy dominance.”
RFA’s comments voice support for EPA’s goal of prioritizing domestic renewable fuels and feedstocks over imported renewable fuels and feedstocks. However, the association believes certain modifications are needed to EPA’s proposed approach to better reflect market complexities in the wake of other recent policy developments, such as the Trump administration’s tariff implementation, modifications of renewable fuel tax credits under the One Big Beautiful Bill Act, and the significant increase in the proposed RVO for biomass-based diesel.
“In the wake of these policy changes, we encourage EPA to consider refocusing potential RIN adjustments more narrowly on imports of finished renewable fuel from countries outside of the United States, Canada, and Mexico, as well as fuels made from certain imported feedstocks (sourced from certain countries of origin) that pose the greatest risk to the integrity of the RFS program,” Cooper wrote. The comments also point out that since corn and sorghum imports are virtually non-existent, EPA’s proposed “feedstock point of origin” tracking requirements are impractical and completely unnecessary for certain renewable fuels like grain-based ethanol.
In addition, while RFA strongly supports EPA’s commitment to reallocating obligated renewable fuel blending volumes lost to small refinery exemptions, Cooper urged EPA to maintain a high standard for determining whether small refineries are truly experiencing “disproportionate economic hardship” (DEH).
“To honor the clear intent and market-forcing purpose of the Clean Air Act’s RFS program, the Agency should maintain a rigorous analytical approach and a high standard of proof for small refiners to demonstrate DEH,” Cooper wrote. “SRE petitioners claiming DEH should be required to provide specific, verifiable data and evidence showing that 1) compliance with the RFS is a central cause of economic difficulty that rises to a level of ‘hardship’, 2) they are truly unable to obtain RINs ‘ratably’ at the same prices as their competitors, and 3) they are somehow unable to pass along their RIN costs in the price of refined products sold to wholesale customers.”
The Friday filing deadline for RVO comments to EPA coincides with the 20th anniversary of the signing of the implementation legislation in 2005 by President George W. Bush. Earlier this week, RFA published a report on ethanol industry successes since this landmark policy was put into place—emphasizing lower gas prices, more energy independence, stronger farms and cleaner air. Click here for Tuesday’s podcast commemorating this anniversary.
