{"id":2240,"date":"2025-06-19T18:47:16","date_gmt":"2025-06-19T18:47:16","guid":{"rendered":"https:\/\/tricordconsulting.com\/?p=2240"},"modified":"2025-06-19T19:58:39","modified_gmt":"2025-06-19T19:58:39","slug":"epas-proposed-rfs-rules-are-refreshingly-bold-and-pragmatic","status":"publish","type":"post","link":"https:\/\/tricordconsulting.com\/index.php\/2025\/06\/19\/epas-proposed-rfs-rules-are-refreshingly-bold-and-pragmatic\/","title":{"rendered":"EPA\u2019s Proposed RFS Rules are Refreshingly \u201cBold\u201d and \u201cPragmatic\u201d"},"content":{"rendered":"\n
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On June 17, 2025, EPA published its proposed rule changes to the Renewable Fuel Standard (RFS).  Public comments are due on August 8, 2025, and with the changes EPA \u201cseeks to<\/em> get the RFS program back on track by establishing renewable fuel volumes for 2027 by the statutory deadline\u201d<\/em> which indicates that they plan to finalize the rule by November 30, 2025.<\/p>\n\n\n\n

In addition to proposing the applicable volumes and percentage standards for 2026 and 2027 for cellulosic biofuel, biomass-based diesel (BBD), advanced biofuel, and total renewable fuel, EPA also proposes several regulatory changes to better align the RFS with the administration\u2019s policy and streamlining objectives.  The following three directional changes appear to return the RFS to its roots as a \u201cliquid fuels\u201d mandate.<\/p>\n\n\n\n

First, EPA affirms its ongoing support for the RFS program by proposing an impressive 67% annual increase in the volume of BBD in 2026 and an additional 4.5% increase in 2027, finally acknowledging the much increased domestic and foreign supply of renewable diesel over the last several years.<\/p>\n\n\n\n

Second, EPA proposes to reduce the number of Renewable Identification Numbers (RINs) generated for imported renewable fuel and renewable fuel produced from foreign feedstocks.  By doing so, EPA refocuses the RFS to its statutory goals of increasing energy independence and energy security.  The increased volume requirements, coupled with a new restriction of 50% less RINs generation for imported renewable fuel and feedstocks, reflect the significant growth potential for renewable fuel production in the U.S. using domestic feedstocks, particularly within the BBD category.  Recognizing the significant impact of the import fuel\/feedstock RINs restriction for 2026 and 2027 BBD volumes as 1.27 and 1.28 RINs per gallon respectively, down from 1.6 RINs per gallon in 2025, EPA\u2019s projections indicate an implicit 25% upside for domestic BBD renewable fuel and feedstocks. Even for the other three renewable fuel categories listed above, this new restriction for import fuel and feedstocks is likely to create modest growth opportunities for domestic production and feedstocks. <\/p>\n\n\n\n

Third, EPA is removing renewable electricity as a qualifying fuel under the RFS, once again confirming its primary role as a liquid fuels mandate.<\/p>\n\n\n\n

In addition to the three major changes listed above, EPA proposes a few more that will streamline and simplify the regulations, such as:<\/p>\n\n\n\n