Today’s article completes the discussion of EPA’s final rule for the Renewable Fuel Standard (RFS). Parts one and two in this series provided background on the RFS, a general review of the final rule and questioned EPA’s definition of the word ‘supply.’ This article delves into whether EPA’s interpretation in general can be considered reasonable […]
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Questioning the Final RFS Rule, Part 2: the Meaning of the Word “Supply”
This article continues the discussion of EPA’s final rule for the Renewable Fuel Standard (RFS). The previous article in this series provided background on the RFS and a general review of the final rule. This article looks specifically at EPA’s interpretation of the word “supply” in the waiver provision “inadequate domestic supply” and what Congress […]
Questioning the Final RFS Rule, Part 1: the Rule and Background
The Environmental Protection Agency (EPA) recently published the final rule that establishes the volume requirements for calendar years 2014, 2015, and 2016 under the Renewable Fuel Standard (RFS). Previous discussions about EPA’s arguments for use of the general waiver authority in the RFS statute reviewed a leaked version of the proposed rule and the proposed […]