The RFS requires Refiners to blend ethanol at the point of distribution or Buy RINs in an effort to streamline compliance.

In a free market economy the consumer should have a choice.. Even though the RFS is SAVING CONSUMERS $$$ by lowering the Costs of GASOLINE..

Again from Irwin.

https://farmdocdaily.illinois.edu/2019/04/revisiting-the-value-of-ethanol-in-e10-gasoline-blends.html

We calculated the energy penalty, octane premium, and net value of ethanol based on weekly prices of ethanol, CBOB gasoline, and aromatics at the U.S. Gulf over the period January 5, 2012 through March 15, 2019.   Similar to our earlier analysis (farmdoc daily, March 15, 2017), the energy-adjusted price of CBOB (assuming ethanol has only two-thirds the energy value of CBOB) was consistently lower than the price of ethanol by an average of $0.56 per gallon.  On the other hand, the price of aromatics, considered as alternative octane enhancers, was consistently above the price of ethanol by an average of $1.24 per gallon.  The net value of ethanol is simply the difference, a positive $0.68 per gallon.  We can roughly estimate that adding ethanol to gasoline saves U.S. drivers 6.8 cents per gallon of finished gasoline (10 percent of $0.68).

The RFS has diversified our nations Liquid energy sources and contributed to more energy security WHILE lowering the Costs of Gasoline to Consumers.

It does not take much to prove this.. look at the Rack Prices for Ethanol vs Unleaded.  http://www.neo.ne.gov/programs/stats/inf/66.html  As you can see since the RFS Ethanol has grown and become Cheaper OVER TIME vs Petroleum alternatives.  In July 2019 the RACK Price of Unleaded averaged $2.11 at Omaha whereas the Rack Price  of Fuel Ethanol averaged $1.31 or $0.80 CHEAPER.



Today I filled up with a 15% ethanol gasoline blend for $2.099 vs the 10% alternative for 2.299.. the Ethanol FREE for $2.599 and Premium for $3.199.  See pics below..

The move to more premium gasolines is underway in this country which contain higher levels of Octane.  Ethanol is a Superior source.

Ethanol is an Excellent solution for our Nations Growing Octane requirements and YES we are selling ethanol in Premium gasoline.  We should re position Ethanol as the Excellent Premium additive which it IS!! 

https://www.eia.gov/analysis/octanestudy/pdf/phase1.pdf

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I would propose that the EPA RE ISSUE the 4.03 Billion gallons of Illegally waived ethanol by Reallocating, and Re Evaluating whom should have received those waivers.

Also a Program whereby Retailers would qualify to issue RIN's up to the costs of Installation of blender pumps.

Installing blender pumps is expensive.  It can cost a retail station upwards of $100,000 or more.  As part of this program a Retailer could Re coup those costs by being Issued RIN's to sell to Obligated Parties up to the level of the Costs of Installation.

4 Billion Illegally Waived Gallons at a RIN's price of $0.20 = $800 million.

I assume that part of those RINs will be incurred with Waivers WHICH SHOULD HAVE NEVER BEEN GIVEN.  However part can go to the installation of Blender pumps.

This is a CONCESSION by the Ethanol industry in that a Gallon of Ethanol blended gasoline sold by a Retailer who qualifies..

As such: any station which has installed or Installs blender pumps can upon completion file for and receive Rins Credits which can be sold.. through a Central Clearing mechanism

Eligible parties include stations who have installed pumps since the Illegal Waivers were issued by Scott Pruitt.. aka 2017.

And any who choose to do so going forth.

As Irwin notes.. the addresses the harm done to ethanol ABOVE the E-10 level.

In Fairness.. this is a tweak to a proposal advanced by Robert Rapier who thinks Midwestern States should take charge of their future and sell E-85.

http://www.rrapier.com/2019/08/how-to-fix-the-ethanol-industry/

How To Fix The Ethanol Industry

The Saudi Arabia of Ethanol

Over the years, I have often referred to Iowa as “The Saudi Arabia of Ethanol.” That was once a more appropriate title when Saudi Arabia was the undisputed king of global oil production, but perhaps less so with the explosion of U.S. shale oil production.

Nevertheless, there are still important elements in the comparison. At present Iowa has the capacity to produce 4.3 billion gallons of ethanol per year, which is 26% of the nation’s total (Source). This is of course due to the large amount of corn production in Iowa, enabled by ample rainfall and rich topsoil.

Saudi Arabia produces 13% of the world’s oil. But Saudi Arabia differs from Iowa with respect to energy production in one very important detail: Saudi Arabia satisfies its own energy needs with the oil they produce, and exports the excess. Iowa produces lots of ethanol, and exports the vast majority of it. Iowa produces no oil at all, but that makes up the vast majority of its energy consumption.

Gasoline consumption in Iowa is presently around 1.5 billion gallons per year (Source). The state consumes another 800 million gallons per year of diesel. According to the Iowa Renewable Fuels Association, gasoline blended with 10% ethanol (E10) makes up about 86% of the fuel supply. E15 and other mid-level ethanol blends (20% to 30%) currently amount to about 9 million gallons per year sold, while 85% ethanol blends (E85) make up another 13.5 million gallons per year.

Add it all up, and Iowa consumes less than 150 million gallons a year of the ethanol it produces. It exports the vast majority, but then it must import gasoline and diesel to meet its fuel needs. Can you imagine Saudi Arabia exporting essentially all of its oil, but then having to import some other fuel to meet its energy needs?

The 4.3 billion gallons per year of ethanol that Iowa produces has the energy content of about 2.6 billion gallons of diesel and gasoline. Thus, Iowa produces more than enough ethanol to be self-sufficient — if it used the ethanol it produces. 

...

Making Iowa Self-Sufficient

If ethanol is a real alternative to gasoline, why don’t Iowans consume as much as they can? Ethanol should have a greater advantage over gasoline in Iowa than probably in any other state. Ethanol should enjoy significant logistical advantages over oil in Iowa.

I tweak his proposal in that I think and Irwin has shown that Ethanol's VALUE is in the Mid Blends.. where it could compete agains PREMIUM Gasoline with it's HIGH OCTANE value.

We should be pushing 93 octane Ethanol blends which could be achieved around a 33% ethanol blend with 83 octane gasoline.. or Some combination of ethanol and a higher octane gasoline.

I would propose that the EPA consider rule making to allow the RFS to address this and meet it's goals.

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