AFPM highlighted the following in its comments:
“The AFPM supports policies that enhance energy security and allow our members to provide the affordable and reliable fuels the American people deserve and expect, goals President Trump shares. Unfortunately, EPA’s proposal for the 2026 - 2027 RFS misses the mark by an Iowa mile – doubling compliance costs from any prior year. AFPM’s recommendations would reduce the cost of this regulation by up to 68%, or nearly US$47 billion each year.
“EPA proposed the costliest RFS mandates since the programme began. The proposed mandates are anticipated to impose nearly US$70 billion in annual compliance costs, nearly double the cost of any previous year. These costs will be borne by refiners, consumers, and the rest of the economy through the increased costs of producing and transporting goods and individual mobility, while inhibiting investment in domestic refining capacity and midstream infrastructure.”
“EPA’s proposal leans on old projections of fuel and feedstock availability, instead of 2025 data. Domestically produced feedstocks and renewable fuels are simply insufficient to meet the sheer magnitude of EPA’s proposed volumes, and, in fact, the proposal would require even more imports.”
Taken together, the following AFPM recommendations would reduce the compliance cost of the RFS proposal by nearly 70%, while still supporting US agriculture and renewable fuel producers:
- Set the implied conventional mandate at the expected ethanol consumption level.
- Set advanced biofuel mandates based on North American feedstock supplies.
- Withdraw the proposed 50% import RIN reduction.
- Finalise adjustments to the 2025 cellulosic biofuel standard.
- Act promptly on outstanding small refinery exemption petitions without reallocating exempted volumes.
- Finalise the rescission of the electric vehicle RIN (eRIN) pathway.