The EPA is expected to submit its proposed 2023 and 2024 renewable fuel standards (RFS) to the White house for final review this week. The proposed RFS standards will likely be similar to those finalized for 2022. However, there is one significant change in the proposed standards that will almost certainly have a significant impact on the liquid petroleum industry. EMA has learned that the EPA is expected to expand RFS by creating a new RIN for electric vehicles charged by electricity generated from biogas and cellulosic biomass. The EPA has the authority to expand the RFS program to include new renewable fuel sources since the statutory volumetric blending mandates imposed by Congress ended in 2022. It is reported the new “e-RIN” would generate a D3 credit under the current RFS regulatory framework.
It remains unclear whether the EPA will establish renewable fuel obligations for electric utilities similar to blending mandates that currently apply to motor fuel refiners. It is possible that automobile manufacturers could wind up generating RINS for electric car production under the new RFS standard. More likely, the agency will allow e-RINS to generate credits and be traded alongside existing RINs without any volumetric blending mandate, similar to RIN generation for renewable heating oil blends. Whichever path the EPA choses, the creation of e-RINs is certain could give a boost to EV sales and new EV charging infrastructure. The EPA is under a consent decree to issue 2023 RFS standards no later than November 16.