Organisation Name
American Petroleum Institute (API)
InfluenceMap Query
Renewable Energy Legislation
Data Source
Legislative Consultations
 
 

Score for this Data / Query Cell

-1.86

InfluenceMap has researched and collated the following pieces of evidence associated with the data source and query indicated above. Extraordinary information is indicated by a coloured flag in the upper right corner. Evidence items in order of data inputted with exceptional items first.

 

Opposing renewable energy standards

InfluenceMap Comment:

Directly advocating EPA to oppose increases in biofuel blending requirements (Submission to EPA by Hunter Hopkins, Exec Director of Georgia Petroleum Council , a division of API, on RFS Standards for 2020 and Biomass-Based Diesel Volume for 2021, November 20th 2019)

Extract from Source:

We are writing to express our opposition to the EPA’s proposal to increase biofuel blending requirements under the Renewable Fuel Standard [...] We urge the EPA to acknowledge these facts and abandon its proposal to reallocate biofuel blending obligations of exempt small refineries, which would increase blending requirements for non-exempt facilities and encourage greater volumes of E15 gasoline.

Created: 07/04/2020 Last edited: 07/04/2020

 

Opposing renewable energy standard

InfluenceMap Comment:

Directly advocating EPA to oppose increases in biofuel blending requirements (Submission to EPA by Mark Harmon, Executive Director of the South Carolina Petroleum Council, a division of API, on RFS Standards for 2020 and Biomass-Based Diesel Volume for 2021, November 25th 2019)

Extract from Source:

On behalf of the South Carolina Petroleum Council, I write to express opposition to the EPA's proposal to increase biofuel blending requirements under the Renewable Fuel Standard. [...] We urge the EPA to acknowledge these facts and abandon its proposal to reallocate biofuel blending obligations of exempt small refineries, which would increase blending requirements for non-exempt facilities and encourage greater volumes of E15 gasoline.  

Created: 07/04/2020 Last edited: 07/04/2020

 

Opposing renewable energy standard

InfluenceMap Comment:

Directly advocating EPA to oppose increases in biofuel blending requirements (Submission to EPA by Chris Zeigler, Executive Director, on RFS Standards for 2020 and Biomass-Based Diesel Volume for 2021, November 25th 2019)

Extract from Source:

We are writing to express our opposition to the EPA's proposal to increase biofuel blending requirements under the Renewable Fuel Standard. [...] We urge the EPA to acknowledge these facts and abandon its proposal to reallocate biofuel blending obligations of exempt small refineries, which would increase blending requirements for non-exempt facilities and encourage greater volumes of E15 gasoline.

Created: 07/04/2020 Last edited: 07/04/2020

 

Opposing renewable energy standards

InfluenceMap Comment:

Directly advocating EPA to reduce more ambitious advanced biofuel target for 2020 and reduce biomass-based diesel standard in 2021 (RFS Public Hearing: API Testimony, July 30th 2019)

Extract from Source:

EPA set an aggressive advanced biofuel target for 2019, and the estimated carryover bank of advanced biofuel RINs decreased significantly. In 2020, Biomass-based diesel is set to increase to 2.43 billion gallons and is expected to fill the gap intended for other advanced biofuels, and the gap in the general renewable category where ethanol is limited by the E10 blendwall. We urge EPA to reduce the advanced biofuel mandate for 2020 to an achievable level, and to reduce the biomass-based diesel standard in 2021. [...] In closing, the proposed volumes are an annual example of a broken government program. Until Congress fixes the RFS through legislation, EPA has the unenviable task of implementing an infeasible mandate. We urge the agency to reject the demands for ever-increasing renewable fuel volumes and act in the best interest of consumers by setting standards that are reasonable, achievable, and fair for all stakeholders

Created: 07/04/2020 Last edited: 07/04/2020

 

Not supporting renewable energy legislation

InfluenceMap Comment:

API is advocating policymakers oppose the reallocation of exempted volumes onto larger refiners and increasing the 2020 RFS Volume standards (Comments on Proposed Rule: Renewable Fuel Standard Program: Standards for 2020 and Biomass-Based Diesel Volume for 2021, and Response to the Remand of the 2016 Standards, Nov 2019)

Extract from Source:

The burden of the Renewable Fuel Standard (RFS) program impacts the entire refining sector with costs that are ultimately borne by consumers. API recommends that EPA establish RFS standards that are consistent with consumption capabilities of the fuels marketplace. […] API opposes EPA’s proposal to reallocate SRE volumes in the 2020 RFS Program. The reallocation of exempted small refinery volumes to other refiners is an additional market distortion that exacerbates this unlevel playing field and punishes non-exempt refiners that are already facing challenging RFS requirements. In addition, reallocation puts unnecessary pressure on the blendwall and increases the overall societal cost of the program. […] API opposes EPA policy that grants a large number of small refinery exemptions, and we strongly oppose the proposal to reallocate exempted volumes as described in the supplemental notice. EPA should not include the proposed changes from the supplemental notice when finalizing the 2020 RFS volume standards. Instead, EPA should finalize the 2020 RFS Rule based on their historical procedures and the July 29, 2019 NPRM. The supplemental notice is a clear demonstration of a failed process and a broken program. EPA is following a flawed directive to “ensure that more than 15 billion gallons of conventional ethanol be blended into the nation’s fuel supply beginning in 2020.”16 The RFS program does not have a mechanism to accomplish this goal, and any additional pressure on the blendwall is more likely to result in additional biodiesel use or a drawdown of carryover RINs. 

Created: 23/01/2020 Last edited: 29/01/2020

 

-- no name --

InfluenceMap Comment:

-- no text --

Extract from Source:

API continues to believe that the RFS should sunset in its entirety by the end of 2022. Mandates and subsidies distort the free market and ultimately increase costs to consumers. For more than a decadealready, the RFS program has mandated the use of biofuels,and fuel suppliershaveresponded by building out the necessary infrastructure to blend ethanolandbiodiesel into our nation’s fuel supply.[...] API opposeslegislation that would establish a 15 billion gallon per year mandate for corn ethanol. It is not feasible for our domestic gasoline market to consume 15 billion gallons of ethanol in 2019due to limitations with the existing vehicle fleet. It would also be infeasible and prohibitively expensive to modify the thousands of retail stations that would require new E15 compatible storage and dispensing systems. [...] Webelieve that the RFS program is outdated and broken, and we support bipartisan efforts in Congress to sunset the program.

Created: 16/01/2019 Last edited: 19/06/2020

 

Opposing renewable energy legislation

InfluenceMap Comment:

Not supporting renewable energy targets within Clean Power Plan (Evidence from joint statement submitted during the EPA's consultation on 'Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units, December 2014)

Extract from Source:

Renewable energy has great promise in Montana and neighboring states, but the ability to construct new wind energy parks is limited by the constraints of the transmission system to send the energy to more populous areas where demand is concentrated, and by the ability of the rest of the generating fleet and the grid to reliably integrate weather-dependent renewable energy which may or may not be generated as needed. These are not intractable problems, but it is clear that the EPA rule has not thoroughly considered them—certainly not on the state-to-state basis that is necessary for the BSER to be adequately demonstrated. As a preliminary matter, the EPA rule is vague and even self-contradicting on the question of which state should get credit for renewables. Should it be the state where the renewable generator is located, or another state where consumers of the energy might reside?

Created: 03/06/2015 Last edited: 29/11/2017

 

Opposing renewable energy standards

InfluenceMap Comment:

Directly advocating EPA to oppose increases in biofuel blending requirements (Submission to EPA by Maureen Ferguson, Executive Director of ABATE of Indiana Petroleum Council, a division of API, on RFS Standards for 2020 and Biomass-Based Diesel Volume for 2021, November 25th 2019)

Extract from Source:

We are writing to express our opposition to the EPA’s proposal to increase biofuel blending requirements under the Renewable Fuel Standard [...] We urge the EPA to acknowledge these facts and abandon its proposal to reallocate biofuel blending obligations of exempt small refineries, which would increase blending requirements for non-exempt facilities and encourage greater volumes of E15 gasoline.

Created: 07/04/2020 Last edited: 07/04/2020

 

Opposing renewable energy standard

InfluenceMap Comment:

Directly advocating EPA to oppose increases in biofuel blending requirements (Submission to EPA by David O'Donnell, Associate Director of the Massachusetts Petroleum Council, a division of API, on RFS Standards for 2020 and Biomass-Based Diesel Volume for 2021, November 25th 2018)

Extract from Source:

We are writing to express our opposition to the EPA’s proposal to increase biofuel blending requirements under the Renewable Fuel Standard [...] We urge the EPA to acknowledge these facts and abandon its proposal to reallocate biofuel blending obligations of exempt small refineries, which would increase blending requirements for non-exempt facilities and encourage greater volumes of E15 gasoline.  

Created: 07/04/2020 Last edited: 07/04/2020

 

Opposing renewable energy legislation

InfluenceMap Comment:

Directly advocating EPA to oppose specific reforms to RFS designed to increase the amount of renewable fuels used in transport fuel (E15/RIN Reform Public Hearing: API Testimony, March 29 2019)

Extract from Source:

EPA’s proposal to extend the RVP waiver to E15 is an anti-consumer policy that goes beyond EPA’s statutory authority and should be withdrawn.[...] To be clear, API is not opposed to using E15 or other ethanol blends in vehicles and infrastructure designed for their use. But EPA is pursuing a policy that puts consumers’ vehicles at risk, potentially forcing them to pay for expensive car repair bills, by pushing E15 into the market before it is ready.[...] The blendwall is the fundamental structural problem with the RFS and RIN reform does nothing to address it. EPA can fix the purported problems these reforms are intended to address by setting feasible annual volume standards that recognize the vehicle and infrastructure limitations to using more ethanol. Blocking access to the market, forcing entities to enter into uneconomic transactions, and disclosing the competitive information of some parties and not others are not measures that prevent RIN market manipulation. On the contrary, these so-called reforms are market manipulation, in a form that is officially sanctioned by the EPA. [...]Attempts to cherry pick certain aspects of the RFS for reform is more evidence that the entire program is a failure.[...] EPA should not finalize either element of this proposed rule. Instead, we urge EPA to focus its attention on protecting consumers from the potential damage to their vehicles that E15 use presents, and to help fix the broken RFS.

Created: 07/04/2020 Last edited: 07/04/2020

 

Opposing renewable energy standard

InfluenceMap Comment:

Directly advocating to EPA to oppose increase in renewable fuel requirements under RFS (RFS Public Hearing: API Testimony, October 30 2019)

Extract from Source:

The misguided policy to reallocate exempt small refinery obligations punishes the companies already complying with a challenging RFS standard. Small refinery exemptions have not materially impacted the amount of ethanol produced or blended into the domestic gasoline pool according to EIA data. Reallocating these exemptions distorts the competitive marketplace and creates an unlevel playing field among competing refineries. We urge EPA to reconsider its decision to reallocate volumes from exempted small refineries onto other obligated parties. […]The RFS is a prospective program, and it would be inappropriate for EPA to artificially increase the renewable fuel requirements to account for prior year issues, including small refinery exemptions. The final standards must recognize it is simply not possible to go back in time and induce demand for a prior year. […] Increasing the implied ethanol mandate above 10% of the gasoline pool does not equate to more ethanol consumption. The blend wall is the constraining factor limiting domestic ethanol use, and despite the recent regulatory action to extend the one-pound RVP waiver to E15, serious vehicle and retail infrastructure compatibility issues remain that will limit the broader use of E15 for the foreseeable future. It is not reasonable to assume E15 or other higher blends of ethanol will lead to ethanol volumes that exceed 10% of gasoline supply in 2020. […] Until Congress fixes the RFS through legislation we urge the agency to reject the relentless demands for ever-increasing renewable fuel volumes and to act in the best interest of consumers by setting standards that are reasonable, achievable, and fair for all stakeholders.

Created: 07/04/2020 Last edited: 07/04/2020

 

Opposing renewable energy legislation

InfluenceMap Comment:

Advocating policymakers to repeal or significantly weaken the RFS (Comment on Renewable Fuel Standard Program: Standards for 2020 and Biomass-based Diesel Volume for 2021, Response to the Remand of the 2016 Standards, and Other Changes, Aug 2019)

Extract from Source:

The RFS mandate is unworkable, and API leads an alliance of diverse interests calling on Congress to repeal or significantly reform the program […] The statutory volumes set in the Energy Independence and Security Act of 2007 are unattainable and maintaining these mandated levels could result in fuel supply disruptions that harm our economy. Congress provided EPA with waiver authority that should be used to reduce the RFS volumes and avoid the potential negative impacts on America’s fuel supply and prevent harm to American consumers. […] EPA should also consider that any volume increase attributed to the 2016 remand should apply to the total renewable volume category only. Some stakeholders at the public hearing on July 31st inappropriately advocated for addressing the court decision by allocating a volume increase across advanced and cellulosic categories; EPA should dismiss those comments.  […] EPA should set volume standards that are achievable in the market and do not require obligated parties to use carryover RINs to demonstrate compliance. Carryover RINs provide flexibility for obligated parties to meet unforeseen events and facilitate market functionality, functions recognized by EPA in this proposal and in previous annual RFS rulemakings. API supports EPA’s decision to not rely on carryover RINs in setting renewable volume standards for 2020. We remain concerned that high advanced biofuel standards could result in a drawdown of the RIN “bank” and recommend that EPA set standards that preserve the carryover RINs inventory by further reducing the advanced and total biofuel requirements. […] The total advanced renewable fuel volume needs to be reduced to avoid potentially dramatic consequences in the biodiesel and renewable diesel feedstock market. […] The RFS is a burden on all refiners, regardless of size, with costs that ultimately impact consumers. EPA should reject calls to reallocate volumes from exempted small refineries onto other obligated parties. Reallocating small refinery obligations punishes complying parties and creates an unlevel playing field among competing refineries putting additional pressure on the blendwall and increasing the overall cost of the program […] API believes that the RFS program is outdated and broken, and we support bipartisan efforts in Congress to repeal or significantly reform the program. Three key assumptions made in 2007 when the Energy Independence and Security Act (EISA) was enacted have since proven to be inaccurate. Congress expected 1) continued growth in fuel demand, 2) increased reliance on imported petroleum, and 3) rapid development of next-generation advanced and cellulosic biofuel technologies. These expectations have not been borne out by reality. Instead, because of technological advances by the domestic oil and natural gas industry, U.S. energy security has improved significantly, and petroleum imports have declined. Ethanol and other biofuels have only marginally contributed to these successes. According to the Department of Energy’s Energy Information Administration (EIA), the RFS “played only a small part in reducing projected net import dependence.”19 It is ultimately up to Congress to repeal or reform the RFS. Meanwhile, API seeks regulatory solutions that: are based on sound science; are achievable for regulated parties; are cost effective for the consumer; and, maintain a level playing field in the market. We urge EPA to use its waiver authority to establish annual volumes consistent with the blendwall, recognizing consumer demand for E0 and the vehicle and infrastructure constraints that limit the sale of E15 and E85. 

Created: 23/01/2020 Last edited: 23/01/2020

 

Not supporting renewable energy legislation

InfluenceMap Comment:

Directly advocating policymakers to support weaker renewable fuel standards (API Testimony at RFS public hearing, July 2018)

Extract from Source:

Our members’ primary RFS concern is the ethanol blendwall. The increases in gasoline demand projected at the inception of the RFS2 in 2007 did not materialize, nor did the commercialization of cellulosic biofuels [...] The RFS is a burden on all refiners, regardless of size, that ultimately impacts consumers. The small refinery exemptions granted by EPA create an unlevel playing field for competing refiners in the marketplace. [...] All of the proposed 590 million gallon increase in the 2019 standard is in the Advanced Biofuel category, and it amounts to a 14% increase from 2018. Biodiesel, which has its own 2.1 billion gallon mandate, is expected to fill the gap intended for other Advanced biofuels, and the gap in the general renewable category where ethanol is limited by the E10 blendwall. Altogether, EPA is proposing a very aggressive Advanced Biofuel mandate that ultimately relies on increased biodiesel imports and carryover RINs to be met [...] We therefore urge EPA to lower the Advanced standard, and similarly, to not increase 2020 Biomass-based Diesel standard. [...] In closing, the proposed volumes are an annual example of a broken government program. We continue to believe the best solution to fix the RFS is comprehensive legislation that includes a sunset of the program in 2022. API continues to work with bipartisan leaders in Congress to come up with a comprehensive approach to fixing the outdated and broken ethanol mandate..

Created: 16/01/2019 Last edited: 13/11/2019

 

Opposing renewable energy standards

InfluenceMap Comment:

Opposing reforms to RFS which would lead to increases in the amount of renewable fuel blended into transport fuel. Additionally, advocating Congress should repeal or significantly reform RFS, as well as arguing the current standards are unattainable and should be lowered (Submission on Modifications to Fuel Regulations to Provide Flexibility for E15; Modifications to RFS RIN market regulations, April 29 2019)

Extract from Source:

API opposes both components of this proposed rulemaking, and we urge EPA to withdraw the rule.  EPA is acting outside its statutory authority in proposing to extend the 1.0 psi RVP waiver to E15 and is proposing RIN market changes that are more likely to cause RIN price volatility rather than prevent it.  EPA’s attempt to cherry-pick certain aspects of this complex program for modification demonstrates why Congress needs to repeal or significantly reform the failed Renewable Fuel Standard (“RFS”). [...]  The statutory volumes set forth by the Energy Independence and Security Act are therefore unattainable.  EPA should address these fundamental problems with the RFS and set volume standards that are achievable in the marketplace and are consistent with the ethanol blendwall.    

Created: 07/04/2020 Last edited: 07/04/2020

 

Opposing renewable energy standard

InfluenceMap Comment:

Directly advocating EPA to oppose increases in biofuel blending requirements (Submission to EPA by John Bargainer, Executive Director of Alabama Petrocleum Concil, a division of API, on RFS Standards for 2020 and Biomass-Based Diesel Volume for 2021, November 21st 2019)

Extract from Source:

We are writing to express our opposition to the EPA’s proposal to increase biofuel blending requirements under the Renewable Fuel Standard. Under this proposal, EPA would willingly allow American consumers to become collateral damage in order to arbitrarily force more ethanol into the marketplace. [...] We urge the EPA to acknowledge these facts and abandon its proposal to reallocate biofuel blending obligations of exempt small refineries, which would increase blending requirements for non-exempt facilities and encourage greater volumes of E15 gasoline.

Created: 07/04/2020 Last edited: 07/04/2020

 

Opposing renewable energy legislation

InfluenceMap Comment:

Directly advocating EPA to oppose specific reforms to RFS designed to increase the amount of renewable fuels used in transport fuel (E15/RIN Reform opening statement, April 25th 2019)

Extract from Source:

We are opposed to incentivizing the use of E15 through extending the waiver as the majority of vehicles and refueling infrastructure are not designed for it. By pursuing this policy and pushing more E15 into the market, the EPA is putting consumers’ vehicles at risk for undue damage, potentially forcing them to pay for expensive car repair bills. In addition to being bad for consumers, this proposal goes beyond EPA’s statutory authority. This proposal conflicts with the clear language of the Clean Air Act. Furthermore it is inconsistent with nearly three decades of EPA statutory interpretation of its authority as well as congressional intent. If this rule is finalized, API will challenge this rule in court.There’s only one answer – this proposal should be withdrawn. [...] The ethanol blendwall is the fundamental structural problem with the RFS, and it should be highlighted that RIN reform does nothing to address this problem. Therefore, EPA should remain focused on simply fixing the blendwall issue by setting feasible volume standards. Attempts to cherry pick certain aspects of the RFS for reform provide more evidence that the entire program is a failure.[...] EPA’s E15 and RIN reform rulemaking is critically flawed. EPA should not finalize either element of this proposed rule. Instead, we urge EPA to focus its attention on protecting consumers from the potential damage to their vehicles that E15 use presents, and to help fix the broken RFS.

Created: 07/04/2020 Last edited: 07/04/2020

 

Opposing renewable energy legislation

InfluenceMap Comment:

Using Covid-19 to advocate EPA to waive reporting requirements for the Renewable Fuel Standard, therefore preventing the enforcements of the RFS (Letter to Andrew Wheeler, Administrator of the Environmental Protection Agency, 23rd March 2020)

Extract from Source:

Industry is seeking temporary relief through enforcement discretion, waivers or revised compliance timeframes in response to the COVID-19 pandemic […]  For certain constraints, we have also identified some specific potential solutions in subbullets. – Fuels reporting and compliance: Request waivers or enforcement discretion for late reports due to access and resource limitations for the following types of reports: Annual gasoline and Renewable Fuel Standard (RFS) reports, […] EMTS RIN requirements for annual compliance with RFS standards. -Annual gasoline and RFS program attest engagements

Created: 30/03/2020 Last edited: 30/03/2020

 

Opposing renewable energy legislation

InfluenceMap Comment:

Directly advocating to policy makers to oppose renewable energy legislation (API comments regarding RFS, Aug 2018)

Extract from Source:

API’s primary concern with the RFS is the ethanol blendwall. The majority of light-duty vehicles on the road today were not designed and warranted for ethanol blends above 10%, and there remain serious vehicle and infrastructure compatibility issues with blends above 10%. [...] The statutory volumes set in the Energy Independence and Security Act of 2007 are unattainable and maintaining these mandated levels could result in fuel supply disruptions that harm our economy. Congress provided EPA with waiver authority that should be used to reduce the RFS volumes and avoid the potential negative impacts on America’s fuel supply and prevent harm to American consumers. [...] API continues to urge EPA to exercise its general waiver authority to reduce the volume requirements based on the severe economic harm rationale as we have articulated in detail to EPA, most recently in comments to the 2018 RVO rulemaking [...] API believes that the RFS program is outdated and broken, and we support bipartisan efforts in Congress to repeal or significantly reform the program.

Created: 16/01/2019 Last edited: 13/11/2019

 

Not supporting renewable energy legislation

InfluenceMap Comment:

Directly advocating to policymakers to support weaker renewable fuel standards (API Comments on 2018 RFS Proposal, August 2017)

Extract from Source:

AFPM and API appreciate EPA’s continuing recognition of the real-world constraints, including anticipated costs that affect the RFS program.8 For 2018, EPA has relied on its cellulosic waiver authority9 to propose reductions in statutory volumes for total renewable fuel, advanced biofuels, and cellulosic biodiesel, but they are not enough. EPA must consider all effects of the E10 blendwall and other constraints and conditions that limit the use of ethanol and other renewable fuel, such as BBD, in transportation fuel. This recognition is key to understanding the real-world limitations on renewable fuel mandates in 2018 and future compliance years. We also support EPA’s proposal to maintain the full amount of RINs that have been reserved, or “banked,” for future use. Clean Air Act (“CAA”) §211(o)(5), which provides for the generation of renewable fuel credits, requires this action. In addition, maintaining a sufficient RIN bank will help mitigate some of the costs imposed by the RFS program, improve flexibility in compliance, and improve the functionality of the RIN marketplace. AFPM and API support EPA’s reduction of the required volumes of renewable fuel in recognition of the real-world constraints on their consumption. We also support EPA’s decision to maintain a sufficient level of “banked RINs” to ensure compliance flexibility and a functioning RIN market. The Agency, however, should further revise the required volumes downward

Created: 29/11/2017 Last edited: 29/11/2017