Letter to EPA: Advocacy Comments on Proposals Regarding the Blending of Ethanol into Gasoline
The U.S. Small Business Administration’s Office of Advocacy (Advocacy) submits the following comments in response to the Environmental Protection Agency’s (EPA) March 21, 2019, notice of proposed rulemaking on “Modifications to Fuel Regulations To Provide Flexibility for E15; Modifications to RFS RIN Market Regulations.” Advocacy believes that EPA’s certification under 5 U.S.C. § 605(b) lacks a factual basis, in part because it does not recognize the directly regulatory impacts on small non-obligated companies that participate in the Renewable Fuel Standard (RFS) program. Advocacy recommends exempting small entities from all of the RIN Market reform proposals.