Point of Obligation Research Documents

A. Administration and Number of Obligated Parties

  1. IHS, RFS Obligated and Non-Obligated Party Lists (April 2016)
  2. Valero/OPIS Analysis of Number of Rack Sellers (June 2016)
  3. Letter from OPIS to EPA (February 21, 2017)

B. Pass Through/Market Frictions

  1. Studies by James H. Stock
  2. Studies by Charles River Associates
  3. Studies by Iowa State University
  4. Studies by Ron F. Minsk

C. Economic and Employment

  1. Alex Holcomb, Market Analysis of the Proposed Change to the RFS Point of Obligation (February, 2017)
  2. Paul Bernstein, et al., NERA Economic Consulting, Effects of Moving the Compliance of Obligation under RFS2 to Suppliers of Finished Products (July, 2015)

D. Retail Market Studies

  1. Bernard L. Weinstein, Southern Methodist Univ., Renewable Identification Numbers (RINs) Trading Under the Renewable Fuels Program – Continued Unintended Consequences for Small Retailers (February 2017)
  2. Ramon M. Benavides, Global Renewable Strategies and Consulting, LLC, The US Renewable Indentification Number RINs Trading Market (August 2016)
  3. Ramon M. Benavides, Global Renewable Strategies and Consulting, LLC, Renewable Fuel Incentives Estimation of Large Retailers’ Margins (February 2017)

E. Fraud Studies

  1. Doug Parker, E&W Strategies, White Paper Addressing Fraud in the Renewable Fuels Market and Regulatory Approaches to Reducing This Risk in the Future (September 4, 2016)
  2. Doug Parker, E&W Strategies, Update to September, 2016, White Paper Addressing Fraud in the Renewable Fuels Market and Regulatory Approaches to Reducing This Risk in the Future (February 2017)

F. National Security

  1. Commander Kirk Lippold Comments


Comments to EPA on Behalf of Coalition

Other Letters to EPA

    • 8.9.16 Letter from Carl Icahn, Icahn Enterprises, L.P.

      “The RIN market is the quintessential example of a “rigged” market where large gas station chains, big oil companies and large speculators are assured to make windfall profits at the expense of small and midsized independent refineries which have been designated the ‘obligated parties’ to deliver RINs.”

      – Carl Icahn

    • 7.15.16 Letter from E. Harvey Steinhagen, III, PetroTex Fuels, Inc.

      “The disproportionate advantages that the EPA has created under the current RPS program allowance utilized by these large retailers has threatened the future of all marketer businesses like mine in industry, and these large retailers have the loudest voices in the national trade associations as you would expect.”

      – E. Harvey Steinhagen

    • 7.11.16 Letter from Bruce W. Heine, Magellan Midstream Partners, L.P.

      “The current definition of obligated party and the RIN compliance scheme can act as a deterrent for renewable fuel demand and infrastructure investment which works against the policy objectives of the Renewable Fuels Standard.”

      – Bruce W. Heine

    • 7.10.16 Letter from Joe Jobe, Rock House Advisors, LLC

      “There is a growing body of compelling evidence to suggest that moving the PO would have large number of benefits for the operation and effectiveness of the RFS for a majority of RFS stakeholders, and for consumers. However, the only way to fully explore and evaluate the impacts of this change is to conduct a rulemaking process where all interested parties can provide input and data to inform the analysis.”

      – Joe Jobe

    • 6.28.16 Letter from Small Retailers Coalition to Janet McCabe, EPA

“The current system needlessly tilts the playing field towards large retailers. By pitting industry segments against one another and creating distinct winners and losers, the current point of obligation threatens everyday consumers. RFS-generated market distortions amount to a huge subsidy for some and a lost business opportunity for others.”

– Bill Douglass

    • Letters have also been submitted by the following retailers:
      • A & T Blacow Gas
      • APCO Petroleum
      • Aycock Oil
      • Bay Oil Company
      • Bellomo Fuel
      • Bravo FueL
      • Brown Oil Distributors
      • CA Fuel
      • Colorado County Oil
      • Dabbs Oil Company
      • Dutchess Terminal
      • M Spiegel and Sons Oil Corp.
      • New Distributing Company
      • Pak Oil Co.
      • 1Pep-Up Inc.
      • Sageland Petroleum
      • Shasta Siskyou Transport
      • Tolino’s Fuel


RINSANITY – Stop the Madness