Document O3b4mvQDz8XqreOoQNmB0amoj

To: leila_getto@ios.doi.gov[leila_getto@ios.doi.gov] From: Mike Sommers, API Sent: 2019-03-06T09:28:13-05:00 Importance: Normal Subject: EPA's Proposed RIN Reform Needs A Closer Look Received: 2019-03-06T09:29:22-05:00 Click to view this email in a browser March 6, 2019 Dear Leila, On Monday, EPA sent its proposal to reform a key component of the Renewable Fuel Standard (RFS) to the White House for review. Unfortunately, a recently released study is the latest in a string of evidence that shows the proposal would only worsen the already broken RFS. In short: the EPA proposal to reform the market for Renewable Identification Numbers (RINs) under the RFS misdiagnoses the problem with the RINs market and provides misguided and counterproductive changes. Contrary to recent EPA commentary, the study finds that RIN price volatility has been the result of the ethanol blend wall as well as EPA's implementation of the program - where EPA regulatory actions, and events that foretell how EPA will set standards, have resulted in RIN price swings. Unless the ethanol blend wall is addressed by reducing RFS standards volumes to feasible levels, fundamental structural problems with the RFS - a key factor that influences RIN price and RIN volatility - will remain. In fact, restricting the RIN market, as proposed by EPA, will exacerbate the already broken fuels mandate which is costly and unnecessary for U.S. consumers. Underpinning these findings is EPA's own previous report showing that refined products reflect the cost of obtaining RINs. The structural changes under consideration are likely to do more harm than good. EPA's attention should be focused on protecting consumers and finding long-term solutions for a program built on an outdated premise, not picking and choosing parts to fix. As the administration evaluates EPA's proposed rulemaking for year-round E15 gasoline sales and biofuels credits reform, it is critical that these anti-consumer policies are given a second look. Mike Sommers President & CEO API The Growing Good-News Story on U.S. Natural Gas There's every reason to believe U.S. natural gas and oil can meet or exceed global expectations. Soaring U.S, crude oil production has increased global supply, supporting the stability of global markets while reducing weekly U.S. crude imports to their lowest level in 23 years (as of Feb. 22). Marketed natural gas production was a record 32.7 billion cubic feet in 2018, the result of modem hydraulic fracturing and advanced horizontal drilling that has driven the energy revolution, and the benefits are just beginning. Find out more. Follow our Blog to stay up-to-date To stay up-to-date on the latest energy-related news, there is no better place to check than the Energy Tomorrow Blog. About API: API is the only national trade association representing all facets of the oil and natural gas industry, which supports 10.3 million U.S. jobs and nearly 8 percent of the U.S. economy. API's more than 600 members include large integrated companies, as well as exploration and production, refining, marketing, pipeline, and marine businesses, and service and supply firms. They provide most of the nation's energy and are backed by a growing grassroots movement of more than 40 million Americans. To learn more about API and the value of oil and natural gas, please visit API.org. Click to view this email in a browser If you no longer wish to receive these emails, please reply to this message with "Unsubscribe" in the subject line or simply click on the following link: Unsubscribe Mike Sommers, API 200 Massachusetts Ave NW Washington, DC 20001 US To: leila_getto@ios.doi.gov[leila_getto@ios.doi.gov] From: Mike Sommers, API Sent: 2019-03-06T09:28:13-05:00 Importance: Normal Subject: [EXTERNAL] EPA's Proposed RIN Reform Needs A Closer Look Received: 2019-03-06T09:29:32-05:00 Click to view this email in a browser March 6, 2019 Dear Leila, On Monday, EPA sent its proposal to reform a key component of the Renewable Fuel Standard (RFS) to the White House for review. Unfortunately, a recently released study is the latest in a string of evidence that shows the proposal would only worsen the already broken RFS. In short: the EPA proposal to reform the market for Renewable Identification Numbers (RINs) under the RFS misdiagnoses the problem with the RINs market and provides misguided and counterproductive changes. Contrary to recent EPA commentary, the study finds that RIN price volatility has been the result of the ethanol blend wall as well as EPA's implementation of the program - where EPA regulatory actions, and events that foretell how EPA will set standards, have resulted in RIN price swings. Unless the ethanol blend wall is addressed by reducing RFS standards volumes to feasible levels, fundamental structural problems with the RFS - a key factor that influences RIN price and RIN volatility - will remain. In fact, restricting the RIN market, as proposed by EPA, will exacerbate the already broken fuels mandate which is costly and unnecessary for U.S. consumers. Underpinning these findings is EPA's own previous report showing that refined products reflect the cost of obtaining RINs. The structural changes under consideration are likely to do more harm than good. EPA's attention should be focused on protecting consumers and finding long-term solutions for a program built on an outdated premise, not picking and choosing parts to fix. As the administration evaluates EPA's proposed rulemaking for year-round E15 gasoline sales and biofuels credits reform, it is critical that these anti-consumer policies are given a second look. Mike Sommers President & CEO API The Growing Good-News Story on U.S. Natural Gas There's every reason to believe U.S. natural gas and oil can meet or exceed global expectations. Soaring U.S, crude oil production has increased global supply, supporting the stability of global markets while reducing weekly U.S. crude imports to their lowest level in 23 years (as of Feb. 22). Marketed natural gas production was a record 32.7 billion cubic feet in 2018, the result of modem hydraulic fracturing and advanced horizontal drilling that has driven the energy revolution, and the benefits are just beginning. Find out more. Follow our Blog to stay up-to-date To stay up-to-date on the latest energy-related news, there is no better place to check than the Energy Tomorrow Blog. About API: API is the only national trade association representing all facets of the oil and natural gas industry, which supports 10.3 million U.S. jobs and nearly 8 percent of the U.S. economy. API's more than 600 members include large integrated companies, as well as exploration and production, refining, marketing, pipeline, and marine businesses, and service and supply firms. They provide most of the nation's energy and are backed by a growing grassroots movement of more than 40 million Americans. To learn more about API and the value of oil and natural gas, please visit API.org. Click to view this email in a browser If you no longer wish to receive these emails, please reply to this message with "Unsubscribe" in the subject line or simply click on the following link: Unsubscribe Mike Sommers, API 200 Massachusetts Ave NW Washington, DC 20001 US