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1. I am struck today by the wildly schizophrenic nature of the Biden Administrations energy policies. Consider what has gone down just with the RFS in recent months. First, they re-opened a previously finalized compliance year, 2020. That had never been done before.
2. Next, they wrote down RVOs for 2020 and 2021 to actual domestic consumption. Finally, yesterday they disallow 1.4 billion gallons worth of 2018 RVOs but then say never mind, no need to actually comply.
3. The picture that emerges is one, at least on the RFS, of an administration that is owned lock, stock and barrel by the crude oil refining industry. Yes, I said that about the Biden Admin EPA. Tell me how this is any different than the Trump Admin?
1. Given strong evidence now that leaked RVO numbers were legit, we can now consider further how the Biden EPA is going to justify the cuts.
2. I have talked a lot about the "intentionally late gambit" for crushing the RVOs, particularly for the conventional ethanol mandate. Biden EPA could clearly use this for cutting 2020 RVO by arguing compliance is late. Probably do so for 2021. But 2022?
3. Since the leaked RVOs included substantial cuts to the conventional mandate for all three years for 2021-2022, I no longer think this is the justification being used to crush the RVOs for all three years. Instead, they went were even the Trump EPA dared not tread.
