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.
https://twitter.com/ChuckGrassley/status/1442881957562626049
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.
4. The most logical explanation for cutting RVOs for all three years is what I call the "little reset" provision in the RFS statutes. The "big reset" is much better known. This is the reset of volumes after 2022 based on broad criteria.
5. The little reset allows a mandate to be written down if it has been cut by 20 % in 2 consecutive years or 50% in one year, but only starting in 2016. Gonna be a legal war over whether you can really apply this to the conventional ethanol mandate. 
6. This is my best guess about what the Biden EPA is trying to use to crush the RVOs for 2020-2022. I honestly cannot think of any other way to justify crushing all three years at this point in time. Always room to be surprised on the RFS though.
7. #grassleyrule under real stress right now in the #RFSwars. Personally, I am truly stunned that the Biden Admin would go down this road on the RFS. As I said before, they must really, really, really hate corn farmers.
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