“The structure of the RFS threatens the future viability of merchant refiners, threatens competition in the transportation fuel sector, has the perverse effect of discouraging high blends of renewable fuel and will ultimately harm the consumer.”

Richard Walsh, Senior Vice President and Deputy General Counsel of Valero
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“RINs have evolved from their intended purpose of facilitating a program where the use of biofuels would be uneven among regions to a commodity that has become a profit center for large fuel retailers with dominant positions in certain geographic markets. This has dramatically increased the costs of implementation for certain obligated parties and disadvantaged consumers.”

Chet Thompson, President of American Fuel & Petrochemical Manufacturers
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“Altering the RFS regulations – so that the obligated party moves from refiners and importers to those making the decisions on who to purchase and blend fuel from – will much better align risk and incentivize due diligence at the appropriate points across the renewable fuels sector.  Absent structural changes in this portion of the RFS regulations, the current point of obligation will continue to contribute to large-scale fraud opportunities within the RFS.”

Doug Parker, Former Director of the EPA’s Criminal Investigation Division
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“Small and medium-size refiners process roughly half the nation’s transportation fuels. Unless the price of credits falls significantly, refinery executives warn of a wave of consolidation that could concentrate refining in fewer hands, leading to higher prices for drivers at gasoline and diesel pumps.”

New York Times: High-Price Ethanol Credits Add to Refiners’ Woes
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“This complex problem has a simple solution: change the point of obligation under the RFS. If the refiner is the also fuel blender, the refiner should remain the obligated party. But if the retailer wants to blend, the obligation should pass to the retailer. This action – which the EPA can accomplish unilaterally through rulemaking – would create a level playing field while still achieving the program’s objectives. In fact, changing the point of obligation would also incentivize blending, thereby advancing the goals set forth by the RFS mandate. The resulting increase in the supply of RINs generated from increased blending would reduce the skyrocketing costs that threaten independent refineries, refinery workers, and consumers.”

George Damiris, CEO of HollyFrontier Corp.
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“RINs continue to be a headwind for the refining industry, and I would like to echo the sentiment of many of our refining peers. The RFS system is absolutely broken. The EPA has the point of obligation in the wrong place and the goals of the program are not being met. While a complete overall of the statute is needed, we feel that at a minimum the EPA should move the point of obligation to where the RIN is generated, as it is done in California with AB32.”

Thomas Nimbley, CEO of PBF Energy
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“The Environmental Protection Agency (EPA) frequently points to national security in its justification for environmental programs. Yet, in spite of the rote frequency with which EPA makes these claims, it has failed to provide any specific or credible analysis to verify the security case for them. If any such meaningful analysis were done, it would likely find that the RFS compliance program with its controversial and costly Renewable Identification Number (RIN) market poses a serious threat to one of the most important components of our national security: a robust United States refining sector.”

Kirk Lippold, Retired U.S. Navy Commander and President of Lippold Strategies
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“The current combination of RFS policy uncertainty, the E10 blend wall, high RIN prices, and low investment means that the RFS currently is imposing costs while failing to provide the future benefits associated with domestic, low-greenhouse gas, second-generation advanced biofuels.”

James Stock, Harold Hitchings Burbank Professor of Political Economy, Faculty of Arts and Sciences and Member of the Faculty at the Harvard Kennedy School
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“By pitting industry segments against one another and creating distinct winners and losers, the current point-of­ obligation threatens everyday consumers. RFS-generated market distortions amount to a huge subsidy for some and a lost business opportunity for others. Aside from considerable losses for small businesses, resultant industry consolidation effectively diminishes retail competition that has been the bulwark against increasing prices at the pump.”

Bill Douglass, Chairman of the Small Retailer Coalition
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“Ironically, the current structure, which puts the point of obligation on refiners instead of where the actual compliance is achieved at the point of blending, provides the least incentive to those who are best situated to undertake the blending that the RFS seeks to motivate and imposes the greatest obligation on the parties who are most poorly situated to increasing the volumes of renewable fuel that is blended into the fuel supply.”

Ronald Minsk, Former Special Assistant to the President for Energy and Environment
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 “The parties on whom EPA continues to impose the compliance obligation – refiners and importers – are the worst situated to encourage blenders or retailers to pass along the value of RINs to the ultimate consumer. Refiners – particularly merchant refiners – have little to no control over the retail markets for biofuels.”

Monroe Energy and Philadelphia Energy Solutions
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“Blenders are using their windfall profits to invest in their own companies – buying back stock and paying dividends – rather than investing in renewable fuel blending, which is the purpose of the [RFS]. The RINs market is arguably one of the largest unregulated commodities markets in the world. It is a black pool, completely secretive and designed to allow speculation and fraud.”

Carl Icahn, Chairman of Icahn Enterprises
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