Document xqMKvxnx724BeNv9z5rJYbQ0
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Jackson, Ryan [/0=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=38BC8E18791A47D88A279DB2FEC8BD60-JACKSON, RY] 12/19/2017 8:40:03 PM McCormack, Brian [Brian.Mccormack@hq.doe.gov] Yunaska, Kyle [Kyle.Yunaska@hq.doe.gov]; Wehrum, Bill [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=33d96ae800cf43a3911d94a7130b6c41-Wehrum, Wil]; Gunasekara, Mandy [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=53dla3caa8bb4ebab8a2d28ca59b6f45-Gunasekara,]; Baptist, Erik [/o=ExchangeLabs/ou=Exchange Administrative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=10fclb085eel4c6cb61db378356aleb9-Baptist, Er] RE: small refinery hardship
Yes, I've cc'd our team. This is a recurring issue which much like PES cannot be addressed individually, but we could address in this year's RVOs should the refinery be eligible.
From: McCormack, Brian [mailto:Brian.Mccormack@hq.doe.gov] Sent: Tuesday, December 19, 2017 12:40 PM To: Jackson, Ryan <jackson.ryan@epa.gov> Cc: Yunaska, Kyle <Kyle.Yunaska@hq.doe.gov> Subject: FW: small refinery hardship
Ryan- per our convo earlier. Can we get our teams together?
From: Henry Barbour [mailto:hbarbour@capitolresourcesllc.com1 Sent: Tuesday, December 19, 2017 12:07 PM To: Susan Butler <sbutler@capitolresourcesllc.com>; McCormack, Brian <Brian.Mccormack@hq.doe.gov>; Yunaska, Kyle <Kyle.Yunaska@hq.doe.gov> Subject: RE: small refinery hardship
Brian and Kyle
Thanks again for the phone visit last week about the small refinery hardship issue. I am just following up to see if you had a chance to visit with Mandy at ERA about this issue.
We are most eager to find a resolution for the small refinery coalition with this incomplete and inconsistent scoring of the existing metrics. We appreciate y'all and your determination to get this right.
Best, Henry
Henry Barbour
601.948,6020 - office I X . 6 - cell
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From: Susan Butler Sent: Thursday, December 14, 2017 12:45 PM To: Brian McCormack (brian.mccormack@hq.doe.gov) <brian.mccormack@hq.doe.gov>; Kyle Yunaska (kvle.yunaska@hq.doe.gov) <kyle.yunaska@hq.doe.gov>
Sierra Club v. EPA 18cv3472 NDCA
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ED 002061E 00051888-00001
Cc: Henry Barbour <hbarbour@capitolresourcesllc.com> Subject: small refinery hardship
Thank you for your time yesterday. In follow up, I just want to reiterate that the small refinery coalition is not asking for something new, but for DOE to exercise oversight over the contractor by having them score the existing metrics which have been in place since 2011 in their entirety, and consistently - both internally and amongst petitioners.
5 of the metrics - for which the data is now available - are not being scored, (l.c. ii and iii, 2. B. ii and iii, and 2.d. highlighted in gray in the table in attached excerpt from the 2011 study). While the data was not initially available in 2011, it has been for several years now - and is submitted in a spreadsheet with the petitions.
It seems unnecessary to have public comment re: whether the existing metrics should be scored correctly and completely...and applied to petitioners consistently.
We recognize that there is a larger debate ongoing re: RFS...and the political reality that it is unlikely to be resolved soon. The hardship process was established by Congress and is intended to mitigate ongoing hardship faced by small refineries under the current law. To that end, there is appropriations report language addressing hardship again this year in both the House and Senate bills.
I have also attached the coalition's more detailed background paper on this. We would be happy to discuss any of this in more detail and look forward to your response. Thank you, Susan
Susan Butler Capitol Resources LLC
915 Prince Street Alexandria, VA 22314
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Sierra Club v. EPA 18cv3472 NDCA
Tier 13
ED 002061E 00051888-00002