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Letter on looming battle for next EPA Administrator

Published by
Hydrocarbon Engineering,

Looking ahead to the Trump administration, there are signs that the Renweable Fuel Standard (RFS) might be on the chopping block or reformed, and a major point of contention if the RFS is reformed is the point of obligation. Despite appearances, a vast majority of refiners do not think it should shift to wholesalers and retailers. They have even joined other companies and organisations across the supply chain in that battle. This level of agreement is unprecedented.

A group of trade associations representing various segments of the fuel industry have signed onto a letter – for the first time ever – that will go to EPA Administrator Gina McCarthy and will help inform the Trump transition team. The letter is in response to the EPA’s proposal and was drafted with the broader fight in mind. It includes a perspective on the RFS that has not been widely covered.

The associations that signed onto the letter represent nearly 13 000 companies that touch numerous aspects of the fuel supply chain, including: major and independent oil refiners; advanced biofuels companies; ethanol producers and supporters; convenience store retailers and suppliers; travel plaza and truck stop owners; petroleum marketing companies that own retail fuel outlets and supply gas; and fuel marketers and chain retailers. They all agree the point of obligation should not change.

A copy of the letter can be viewed below:

Dear Administrator McCarthy,

The undersigned associations represent a significant majority of participants across the United States’ transportation fuels value chain. While each association has an individual, unique position – often conflicting –regarding the broader Renewable Fuel Standard (RFS) programme, we write to express our unified position in opposition to efforts by petitioners to move the point of obligation for RFS compliance. It is unprecedented for all of these undersigned groups to unite in a single letter to express a uniformly held position.

Each of the undersigned associations strongly supports the Environmental Protection Agency’s (EPA) proposed denial of petitions for a rulemaking to change the point of obligation under the RFS. There is no sound public policy rationale for moving the point of obligation and further, such a change would add complexity and uncertainty to the current RFS programme. We urge EPA to finalise its conclusion and deny the petitions to move the point of obligation.


  • American Petroleum Institute
  • Advanced Biofuels Association
  • Growth Energy
  • National Association of Convenience Stores (NACS)
  • National Association of Truck Stop Operators (NATSO)
  • Petroleum Marketers Association of America (PMAA)
  • Society of Independent Gasoline Marketers of America (SIGMA)
  • Renewable Fuels Association

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