1. Back to our regularly scheduled programming. A very nice article from @toddneeleyDTN on the lead up to the release of the EPAs 2019 proposed rulemaking. Much to absorb about the process in this article: dtnpf.com/agriculture/we…
@toddneeleyDTN 2. Did some digging on my own this morning and found within the docket for 2019 rulemaking a version of the rulemaking dated June 21, 2018. The email it is attached to indicates this was the official working version of the proposal at that point.
@toddneeleyDTN 3. Here is the link to the June 21 version of the 2019 rulemaking file:///C:/Users/sirwin/Downloads/Email_from_Tia_Sutton_to_Chad_Whiteman_regarding_Updated_version_of_2019_RVO_NPRM.pdf
@toddneeleyDTN 4. The email between OMB staffer Chad Whiteman and EPA staffer Benjamin Hengst . They were clearly pinging back and forth on the official version of the 2019 rulemaking 
@toddneeleyDTN 5. The key material for SREs is on pp. 72-76. This page shows the discussion why it is reasonable and LEGAL for the EPA to project the volume of SREs for 2019. I loved the footnote quoting the definition of "project"
@toddneeleyDTN 6. The next page shows that on June 21 the proposal included a projection of gasoline and diesel use for small refineries of 13.62BGs, a bit less than the 15BG we assumed in our #FDD yesterday (wish I would have found this yesterday!). No zeros at the bottom of the table
@toddneeleyDTN 7. And here are the percentage standards in this version of the proposal.
@toddneeleyDTN 8. Just 5 days after this version of the proposed 2019 rulemaking was circulating officially between agency personnel it was dramatically revised to the "scorched earth" SRE version that was officially released.
@toddneeleyDTN 9. Of course, the only version that matters is the final version that was released. But I think this version is important because it shows there is indeed a very reasonable argument for projecting SREs that was adopted by the EPA for at least part of the process.
@toddneeleyDTN 10. I challenge all those out there opposed to the reallocation of SREs to read this version of the rulemaking and provide a compelling counter-argument. I think the reason that EPA shut off comments is because the compelling counter-argument does not exist.
@toddneeleyDTN 11. Fascinating how the #RFSwars turn on the legal interpretation of just a few words. First is was "supply" in "inadequate domestic supply" and now it is "projected" in "amount of gasoline and diesel projected to be produced by exempted small refineries."
