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Re:

Did Oil Refiners Get Back in the Driver’s Seat on the RFS?

Scott Irwin’s December 2024 forecast anticipated more small-refinery exemptions and pressure to reduce ethanol requirements. EPA’s later RFS actions were mixed.
From TheFinanceBase Team3 min to read
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Not entirely. In December 2024, University of Illinois biofuels analyst Scott Irwin forecast that the incoming Trump administration might grant small refineries more exemptions and seek to reduce ethanol requirements. EPA’s subsequent actions have been mixed: it set substantial renewable-fuel requirements for 2026 and 2027, while granting many refineries full or partial relief for 2025 compliance. As of October 8, 2026, an additional proposed reallocation of 2025 exemptions had not been finalized.

What Irwin meant by “back in the driver’s seat”

Irwin made the comment while discussing what he expected from the incoming administration, not reporting a policy decision already made. In a December 12, 2024 report on a farmdoc daily webinar, he said: “We should assume refiners will be back in the driver’s seat,” and described the outlook as “a bumpy and turbulent ride figuring out how this is all going to net out for biofuels.” His forecast was that the administration might approve small-refinery exemptions more liberally and push to lower ethanol requirements. Successful Farming’s December 2024 report presented this as an uncertain outlook, not a settled outcome.

That report also cited historical context: corn ethanol use was 12.5 billion gallons in 2020, and EPA issued dozens of small-refinery exemptions during Trump’s first term. It reported 2025 requirements of 15 billion gallons of corn ethanol and 7.4 billion gallons of advanced biofuels. Those figures describe what the December 2024 article reported; they are not a substitute for EPA’s later standards.

How the later EPA actions compare

The Renewable Fuel Standard (RFS) operates through more than one policy lever. EPA sets renewable-fuel volume obligations, and it may grant qualifying small refineries exemptions. When exemptions reduce required volumes, EPA’s treatment of those waived amounts—including whether it reallocates them—also matters. The later record points in different directions on those levers.

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Policy action What EPA did What it indicates
2026–2027 volume standards Finalized total applicable volumes of 26.81 billion RINs for 2026 and 27.02 billion RINs for 2027. Substantial overall renewable-fuel obligations, rather than a general reduction in the standards.
Reallocation of earlier exemptions Included a 70% reallocation of small-refinery exemptions granted for 2023–2025. Some exempted volume was put back into obligations for other parties.
2025 small-refinery petitions Granted 18 full and 11 partial exemptions among 34 petitions for 2025 compliance; denied three and found two ineligible. Many individual refineries received relief, although not every petition did.
Further 2025 reallocation Announced plans to propose full reallocation of the difference between projected and actual 2025 exemptions into 2026 and 2027 obligations. As of October 8, 2026, this further step remained a proposal, not a finalized action.

EPA’s March 27, 2026 final standards set total applicable renewable-fuel volumes at 26.81 billion RINs in 2026 and 27.02 billion in 2027. A RIN is equivalent to one ethanol-equivalent gallon of renewable fuel. The same rule reallocated 70% of small-refinery exemptions granted for 2023–2025 and removed renewable electricity as a qualifying fuel under the RFS.

What the 2025 refinery exemptions show

On August 31, 2026, EPA decided 34 petitions from refineries seeking exemptions for the 2025 compliance year. Its announcement records 18 full exemptions, 11 partial exemptions, three denials and two ineligible petitions. EPA said it exempted 1.76 billion RINs for 29 small refineries.

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That is meaningful relief for the refineries granted full or partial exemptions. It does not, on its own, establish that the administration lowered the RFS volume standards overall: EPA’s separate final rule set the 2026 and 2027 total volumes and included reallocation of a portion of earlier exemptions. The record therefore supports a mixed assessment, rather than a simple verdict that refiners either did or did not regain control.

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What was still unresolved on October 8, 2026

EPA said it would propose, before the end of October 2026, full reallocation into 2026 and 2027 obligations of the difference between projected and actual exempted volumes for 2025. Its release also said it would extend the 2025 RVO compliance date to October 1, 2026. The additional reallocation was prospective as of October 8; it should not be described as finalized on the basis of that announcement.

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The available actions establish how EPA handled standards and exemption petitions, but they do not quantify the net economic effect on refiners, biofuel producers or consumers. Whether Irwin’s forecast proved right therefore depends on which lever is in view: refineries received substantial case-specific relief, while the finalized overall volumes remained high and some earlier exemptions were reallocated.

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