RINs Higher Despite Lower Proposed 2020 & 2021 RVOs
The proposed RVO requirements are not final but the market seems to understand the underlying message. EPA is attempting to satisfy both sides of the never-ending conflict between renewable fuels and oil. Ignore that the RVOs are based on percentages and are self-correcting regardless of whether actual volumes exceed or retreat from forecasted numbers. EPA desires to move past this conflict and may be stretching limits by reducing the 2020 RVO Final Ruling and going below statute on the 2021 proposal. However, they are offering an olive branch alongside the proposed RVOs.
Separately, EPA has proposed denying all 2019 and 2020 small refinery exemptions (SREs) and is currently taking comments on the proposal.
EPA has conducted extensive analysis and review of information provided by small refineries in their SRE petitions to the…
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