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ARTICLE · 30 SEPTEMBER 2025

EPA Proposes RFS Supplemental Rule, Addresses Small Refinery Exemptions

Bergeson & Campbell
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As reported in our June 18, 2025, blog item, the U.S. Environmental Protection Agency (EPA) proposed in June 2025 the applicable volumes and percentage standards...

United StatesEnvironment
Lynn L. Bergeson Esq.
Lynn L. Bergeson Esq.
Carla Hutton
Carla Hutton
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As reported in our June 18, 2025, blog item, the U.S. Environmental Protection Agency (EPA) proposed in June 2025 the applicable volumes and percentage standards for 2026 and 2027 for cellulosic biofuel, biomass-based diesel (BBD), advanced biofuel, and total renewable fuel. On September 18, 2025, EPA issued a supplemental notice of proposed rulemaking (SNPRM) that revises the proposed Renewable Fuel Standard (RFS) "Set 2" renewable volume obligations (RVO) for 2026 and 2027 to account for the expected impacts of the small refinery exemption (SRE) petition decisions that EPA issued in August 2025. 90 Fed. Reg. 45007. Based on this information, EPA is co-proposing additional volumes in 2026 and 2027 representing complete (100 percent) reallocation and 50 percent reallocation for SREs granted in full or in part for 2023 and 2024, as well as those projected to be granted for 2025, as part of the ongoing RFS rulemaking. EPA is also providing more information on its

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