Scheduled Retirement Plan for Small Refineries under the RIN Program's Final Option
EPA Announces Alternative RIN Retirement Schedule for Small Refineries in Response to 2020 Compliance Year Challenges
The Environmental Protection Agency (EPA) has announced an alternative Renewable Identification Number (RIN) retirement schedule for small refineries, effective from the 2020 compliance year. This decision was made due to extenuating circumstances that affected the small refineries during that period, notably the COVID-19 pandemic and fluctuating market conditions.
The alternative RIN retirement schedule provides small refineries with additional time and flexibility to comply with their Renewable Fuel Standard (RFS) obligations. Instead of requiring the full RIN retirement by the standard deadline, the EPA allows these refineries to retire RINs over an extended, staggered timeline. This approach is designed to avoid market disruption while still maintaining the integrity of the RFS program.
The EPA recognises the extenuating circumstances that small refineries faced during the 2020 compliance year, including limited availability of RINs and delays in EPA's decisions on Small Refinery Exemption (SRE) petitions. The policy includes consultation with the Department of Energy, which helps assess hardship for small refinery applicants.
This alternative schedule is part of a broader effort to address small refinery exemptions and compliance flexibility across multiple years. The final rule for the Renewable Fuel Standard (RFS) Program: Alternative RIN Retirement Schedule for Small Refineries was published on September 2, 2022, under the docket number EPA-HQ-OAR-2022-0434 and pertaining to 40 CFR Part 80.
It's worth noting that the detailed specific timetable or deadlines for the phased RIN retirements were not disclosed in the directly available documents. However, the policy context and rationale are well documented in industry and EPA communications from that period.
This alternative RIN retirement schedule expands the range of RINs small refineries can use to comply with their 2020 RFS obligations. The policy is intended to minimise legal risks and market disturbance while fairly accommodating small refinery compliance challenges during an unprecedented year.
No further information about proposed alternatives or denied petitions for RFS Small Refinery Exemptions was provided in the given paragraph. The EPA's action on August 29, 2022, addressed the small refinery petitions related to 2020 by granting extensions for RIN retirements based on documented extenuating circumstances.
[1] References: Industry communications and EPA communications from the period in question.
The alternative RIN retirement schedule, introduced by the EPA, allows small refineries to retire Renewable Identification Numbers (RINs) over an extended period, accommodating financial difficulties arising from the 2020 compliance year's unique challenges, such as COVID-19 pandemic and market fluctuations. Moreover, this approach in the energy sector, aimed at maintaining the Program's integrity, expands the range of RINs small refineries can use to meet their 2020 Renewable Fuel Standard (RFS) obligations, thereby minimizing legal risks and market disturbance.
