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Waiver Comments
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Posted 4/15/2019 15:31 (#7441001 - in reply to #7440469)
Subject: RE:"Kiss your corn ethanol market goodbye"

I've tried twice now to copy and paste parts of EPA's proposed modification to RINs system also included in this same rule change. Both times it appears that there is hidden code embedded in the text that prevents Agtalk from uploading it.
But anyhow, the E15 rule change is very straight forward and should be accepted without controversy. Simply put the Reid vapor pressure requirement for E15 is the same as it is for E10.

However, it is clear that the proposed modifications will render the RINs mechanism to insure ethanol blending useless. Among the changes are, only those obligate parties who blend ethanol can purchase separated RINs.. Producers of separated RINs will only be able to sell them to other users of RINs. In other words, fuel producers who chose not to blend get to buy RINs at the price they chose.
In addition, fuel producers who fail to blend their required allocation of ethanol in any given year have their obligation disappears at the end of the year. How convienent is that?

There are other issues as well.
These rule changes essentially "guts" the RFS as far as corn ethanol goes.
If corn farmers do anything today, they need to respond to this call for public comment and send a protest to their elected representatives.
Otherwise, they can just "kiss their corn ethanol market goodbye"
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