Thread by @ScottIrwinUI

1. @OPISBiofuels reporting today ***Ethanol RINs Dip Below $1 on 'Leaked' RVO Proposed Volumes. Start with conventional mandate numbers supposedly leaked.

@OPISBiofuels 2. According to OPIS "The volume totals were 12.5 billion gal of conventional fuel in 2020
-- well below the previously finalized 15.0 billion gal -- 13.453 billion gal in 2021 and 14.096 billion gal in 2022."

@OPISBiofuels 3. Assuming these are accurate, a whole host of issues raised. First, how can you ex post justify cutting a previously finalized RVO by 2.5 billion gallons? Did they go whole hog on the "compliance is not finalized/intentionally late legal gambit"?

@OPISBiofuels 4. The 12.5 billion gallon figure for the conventional mandate in 2020 is very close to my computation of domestic ethanol disappearance for 2020. My estimate is 12.6 billion gallons. Sure looks like it is 2014 and 2015 all over. Compliance is late so just set it at actual.

@OPISBiofuels 5. But this seems to me to be stretching the definition of "late." Extremely confident that ag groups will challenge this very quickly in court. Just a guess but I think they will mount a strong legal challenge.

@OPISBiofuels 6. The conventional mandate level of 13.453 billion gallons of 2021 looks like more of the same. Very close to projected domestic ethanol disappearance in 2021. Again, stretching the definition of "late." 2021 is not even over yet.

@OPISBiofuels 7. The one that really surprises me (again if accurate) is 14.096 billion gallons for 2022. What possible legal argument is available for waiving the implied conventional mandate by a billion gallons at this point in time? Perhaps some new environmental waiver???

@OPISBiofuels 8. If the leaked numbers are accurate, the politics are absolutely fascinating. Talk about flipping off Corn Belt ag. The message could not be blunter: The Biden Admin really, really does not like corn farmers.