The RFS has been an ongoing point of contention between major players in the fuel industry. A handful of refiners and investors have petitioned the EPA to shift compliance requirements down the supply chain. Doing so would undercut the program's efforts to sustain the use of renewable fuels in gasoline and diesel fuel. The current structure creates a strong incentive for blenders, retailers and marketers to integrate renewable fuels into the supply chain.
"The RFS is working as intended by creating stable gas prices and encouraging renewable fuels in our gas supply," said Tim Columbus, general counsel of the National Association of Convenience Stores and SIGMA. "But if the EPA shifts compliance, it would unnecessarily complicate the program, needlessly disrupt the markets for motor fuels, and hurt consumers most."
In addition to undermining the purpose of the program, this change would increase gas prices for consumers as downstream players' ability to satisfy their obligations would be dictated by upstream counterparts, who have the leverage and incentive to raise prices. A recent Penn Schoen Berland (PSB) survey released earlier this year revealed that 86 percent of voters agree that a compliance shift would increase gas and diesel prices at the pump.
The change would also add significant compliance costs and burdens to freight shippers, which would ultimately raise the cost of consumer goods through higher shipping costs. For example, if the compliance changes, Class I railroads would need to expend between $112.5 million and $214 million just to acquire Renewable Identification Numbers (RINs) to comply with 2016 Renewable Volume Obligations (RVOs) – based on 2016 numbers. California's enactment of the Low Carbon Fuel Standard is a cautionary tale. In light of the market's experience in California, it would not be implausible for the railroads to have to pay between $260 and $447 million more for fuel.
Following is a list of the diverse group of associations and companies that submitted comments in support of keeping the current compliance requirements:
To learn more about this issue, read the RFS And Compliance Requirements fact sheet here and What People Are Saying about the RFS here.
NATSO is the trade association of America's travel plaza and truckstop industry. Founded in 1960, NATSO represents the industry on legislative and regulatory matters; serves as the official source of information on the diverse travel plaza and truckstop industry; provides education to its members; conducts an annual convention and trade show; and supports efforts to generally improve the business climate in which its members operate.
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SOURCE NATSO, Inc.