On Friday, October 21, NEFI submitted comments to Lee Zeldin, EPA Administrator, on the Renewable Fuel Standard (RFS) Program: Standards for 2026 and 2027, Partial Waiver of 2025 Cellulosic Biofuel Volume Requirement, and Other Changes, as per the Supplemental Notice of Proposed Rulemaking issued September 18, 2025.

These comments reiterated NEFI's support for the proposed increase in volumes for biomass-based diesel and advanced biofuels. With regard to the Supplemental Notice, the comments said, "In particular, the Supplemental Notice recognizes that the 'availability of these RINs—and the ability for obligated parties to use them to comply with their RFS obligations in lieu of RINs generated for renewable fuel produced and used in 2026 and 2027—could reduce RIN demand and RIN prices in future years and may ultimately result in the market failing to produce the volume of renewable fuel anticipated by the volume requirements in the Set 2 proposal.' As such, the heating oil industry is concerned with the potential impacts of these SREs to undermine the incentives to invest in biofuels and to reduce biofuel production."

"Allowing SREs to undermine the incentives Congress created to promote increased production of fuels would be counter to Congress's directives and the market-forcing purposes of the program. As such, we support EPA's proposal to provide for SRE reallocation volumes to mitigate against the deleterious effects of the 2023-2025 SREs and believe those volumes should represent 100% of the exempted volumes."