API Letter to EPA expressing opposition to moving the point of obligation under the RFS program
API President and CEO Jack Gerard's letter to EPA Administrator Gina McCarthy concerning API's opposition to moving the point of obligation under the Renewable Fuel Standard (RFS) program.
Changing the point of obligation under the RFS will not fix the blendwall problem or meaningfully impact the overall volume of renewable fuels. Any adjustment to the point of obligation 9 years into the program would create uncertainty in the administration of the RFS and, potentially, in the RIN market. RFS compliance plans, investments and commercial agreements that were premised on the current structure would be disrupted. Furthermore, moving the point of obligation would not address vehicle compatibility and consumer acceptance issues, nor would it address infrastructure constraints throughout the distribution system that inhibit greater penetration of E15 and E85. Simply put, moving the point of obligation will merely shift the compliance responsibility under the RFS from the current group to a different group of entities in the fuel supply chain.
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