US EPA opens comment period on RFS point of obligation proposal

By Ron Kotrba and Erin Voegele | November 22, 2016

The U.S. EPA has published a notice in the Federal Register proposing to deny several petitions requesting the agency redefine the point of obligation under the renewable fuel standard (RFS), officially opening a 60-day public comment period on the proposal. The EPA released a prepublication version of the proposal Nov. 10.

Several refiners and organizations have petitioned EPA to move the point of obligation downstream. EPA said it believes that a change in the point of obligation would be a substantial disruption with the potential to undermine the success of the RFS program. The agency also said changing the point of obligation would likely disrupt investments already made by those who have relied on the regulatory structure established in 2007 and reaffirmed in 2010, and delay future investments. EPA also stated the change would vastly increase the complexity of the RFS program, causing confusion and uncertainty.

EPA is specifically requesting comments that address whether changing the point of obligation would be likely to significantly increase production, distribution, and use of renewable fuels in the U.S., as well as data substantiating those claims. 

Public comments on the proposal will be accepted through Jan. 23. Comments can be filed online at under Docket ID No. EPA-HQ-OAR-2016-0544. Additional information is available on the Federal Register website.


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