Public Comments to the EPA

• CVR Energy Comments to the EPA’s Proposed Response to Requests to Change the Point of Obligation in the RFS Program (Feb. 22, 2017)
• Oil Price Information Service (“OPIS”) Comments to the EPA’s Proposed Response to Requests to Change the Point of Obligation in the RFS Program (Feb. 21, 2017)
• Joe Jobe’s Comments to the EPA’s Proposed Response to Requests to Change the Point of Obligation in the RFS Program (Feb. 22, 2017)
• Ronald E. Minsk’s Comments to the EPA’s Proposed Response to Requests to Change the Point of Obligation in the RFS Program (Feb. 22, 2017)
• Small Retailers Coalition Comments to the EPA’s Proposed Response to Requests to Change the Point of Obligation in the RFS Program (Feb. 20, 2017)
• Phillips 66 Company Comments to the EPA’s Proposed Response to Requests to Change the Point of Obligation in the RFS Program (Feb. 17, 2017)
• Commander Kirk S. Lippold, USN (Ret) Comments to the EPA’s Proposed Response to Requests to Change the Point of Obligation in the RFS Program (Feb. 8, 2017)
• Bob Neufeld’s Comments to the EPA’s Proposed Response to Requests to Change the Point of Obligation in the RFS Program (Jan. 30, 2017)
• National Electrical Contractors Association (PENN-DEL-JERSEY Chapter) Comments to the EPA’s Proposed Response to Requests to Change the Point of Obligation in the RFS Program (Feb. 22, 2017)
• United Association of Journeymen and Apprentices of the Plumbing and Pipe Fitting Industry of the Unites States and Canada Comments to the EPA’s Proposed Response to Requests to Change the Point of Obligation in the RFS Program (Feb. 22, 2017)

Letters and Petitions to the EPA

• Monroe Energy Letter Regarding Carl Icahn’s WSJ Op-Ed: If Oil Refiners Crash, So Will the Economy 
• Open Letter to Consumers, Congress and the EPA from CVR Refining CEO Jack Lipinski
• CVR Refining Comment on 2014-2016 RFS Rule
• Monroe Energy and Philadelphia Energy Solutions Comment on 2014-2016 RFS Rule
• Ronald Minsk, Former Special Assistant to President Obama for Energy and Environment, Comment on 2014-2016 RFS Rule
• Small Refiners Coalition Comment on 2014-2016 RFS Rule
• Valero Comment on 2014-2016 RFS Rule
• CVR Energy Comment on 2017 RFS Rule
• Monroe Energy Comment on 2017 RFS Rule
• Small Refiners Coalition Comment on 2017 RFS Rule
• Valero Comment on 2017 RFS Rule
• AFPM Petition to EPA: Obligated Party Definition Needs to Change
• HollyFrontier Corp. Petition to EPA: Obligated Party Definition Needs to Change
• Valero Petition to EPA: Obligated Party Definition Needs to Change
• CVR Energy Amicus Brief in Support of Changing the Point of Obligation
• Small Retailers Coalition Amicus Brief in Support of Changing Point of Obligation
• Icahn Enterprises Chairman Carl Icahn: The RIN Market is Rigged
• Renewable Fuels Association: EPA Must Investigate RIN Market Manipulation

White Papers, Studies and Reports

• Fixing the Renewable Fuel Standard 
• RIN Trading under the RFS: Unintended Consequences for Small Retailers
• The Renewable Fuel Standard: A Path Forward
• Addressing Fraud in the Renewable Fuels Market and Regulatory Approaches to Reducing This Risk in the Future
• NERA Report: Effects of Moving the Compliance Obligation
• NERA Report: Analysis of RINs Markets
• Baker & O’Brien: Absolute RIN Purchases
• Gasoline Cracks and Ethanol RINs