In Halloween comments, IRFA calls on EPA to end RFS tricks and treats by fully reallocating refinery exemptions
- Iowa Renewable Fuels Association
- Nov 3
- 2 min read
The Iowa Renewable Fuels Association submitted formal comments Oct. 31 to the U.S. EPA’s supplemental proposed Renewable Fuel Standard blending rule for 2026-’27.
As part of that proposed rule, EPA is evaluating whether to reallocate 100 percent or 50 percent of refinery exemptions granted for 2023 and 2024, as well as those anticipated for 2025.
In its comments, IRFA strongly supported EPA’s proposal to reallocate 100 percent of the 2023-’25 small-refinery exemptions (SREs) while cautioning that “reallocating the SREs means nothing without finalizing the robust RFS blending levels proposed by the agency for 2026-’27. Combining these actions will be like giving the renewable fuels market a full-size candy bar on Halloween and not one of those mini versions.”
Key points from IRFA’s comments include:
Maintain and finalize the robust blending level proposal for 2026-’27: “IRFA strongly supports and urges the EPA to adopt the proposed RFS blending levels in the final rule.”
SREs should be few and fully reallocated: “IRFA still strongly believes that the best way for the EPA to maintain the integrity of the RFS, to provide market certainty and to ensure farmers, renewable fuels producers and obligated parties are treated fairly is to ensure the granted SREs are few and fully reallocated.”
SRE tricks should not be rewarded with treats: “IRFA strongly echoes the attorneys general request that EPA not reward these potential tricks with SRE treats, and for EPA to engage with the SEC and all relevant federal agencies to ensure no refiner is misleading either the agency or public shareholders.”
EPA must fully reallocate 2023-’25 RFS exemptions to prevent demand destruction: “IRFA urges the agency to finalize the 2026-’27 RFS blending rule with the robust standard volumes as previously proposed combined with additional SRE reallocation volumes designed to account for 100 percent of the 2023-’25 SREs.”
50 percent reallocation simply does not make logical sense: “IRFA feels strongly that to suggest—after RFS rules have been proposed—that some of the zombie RINs are needed for RIN flexibility is illogical and would be detrimental to farmers while providing a windfall to refiners.”
Reallocation over two years is appropriate, but 100% reallocation is paramount: “As illogical and unsupportable as it would be, if EPA ultimately determines that 100 percent reallocation over 2026-’27 is not possible, the agency should not undermine the RFS with 50 percent reallocation. Instead, in that scenario, IRFA urges the EPA to reallocate 100 percent of the 2023-’25 exemptions over four years.”
In conclusion, IRFA stated, “By getting the RFS back on track with robust, market-moving RFS blend levels and fully reallocating the 2023-’25 SRE zombie RINs, EPA can take the first step to turn around a struggling farm economy while boosting consumer access to lower-cost, home-grown fuels, and taking another step toward American energy dominance.”
To read IRFA’s full comments, click here.
