1. Now back to the #RFSwars. The Trump Admin is clearly going to be looking for a way to address refiner concerns after the #SRE program was just flushed down the toilet They might want to take a look at a proposal I made last Sep farmdocdaily.illinois.edu/2019/09/cleari…
2. Probably would take Congressional action, but I still think a reasonable way to go is to issue a blanket waiver for all small refineries at the time of final RVO rulemakings. Addresses the stated concerns of all small refiners in one fell swoop.
3. Key is that blanket waiver has to be made at the time of final RVO rulemaking so the obligation of small refiners is reallocated to the larger refiners. For now, forget the second part of my proposal of reallocating past SREs. Just focus on a blanket waiver going forward.
4. Call the bluff of the refiners that this is about economic hardship of small firms. While there are some that really believe small refiners take a financial hit, I don't think this is the real reason that refiners pushed so hard on SREs.
5. It should really be obvious by now that refiners simply want to kill the #RFS by any means possible. That is the real goal. And their arguments are not entirely without merit. However, it is the law of the land that only Congress can and should change it.
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