Dear Members of Congress,

On behalf of a broad and diverse coalition representing fuel refiners, ethanol producers, agriculture stakeholders, and fuel retailers, we write to express our strong support for the bipartisan amendment #289 to the House Farm Bill that would allow for the year-round sale of E15 fuel and provide reasonable, targeted reforms to the Small Refinery Exemption process under the Renewable Fuel Standard, which was introduced by Representatives Michelle Fischbach, Randy Feenstra, Stephanie Bice, and Adrian Smith.

This amendment reflects a unique area of agreement across the fuel and agriculture supply chain. While our industries do not always see eye to eye, we are united in the belief that these policy reforms provide needed certainty, preserve consumer choice, and support
agriculture and energy economies alike.

Importantly, this amendment does not mandate the sale of E15. Instead, it simply allows retailers to offer E15 to consumers during the summer months if they choose to do so. Maintaining access to E15 year-round empowers consumers at the pump with more options, particularly during periods of tight supply and high fuel costs, while allowing refiners and retailers to meet the demands of the market.

Year-round E15 sales also provide clarity and stability for farmers and biofuel producers who rely on consistent market access for the crops they grow and the fuels they produce. Predictable policy signals reduce risk, encourage investment, and help sustain jobs throughout rural communities without imposing new regulatory burdens.

In addition, the amendment’s reasonable reforms to the Small Refinery Exemption process will help restore transparency and predictability for all parties subject to the Renewable Fuel Standard. A clear and consistent approach ensures that exemptions are applied as Congress intended, while avoiding uncertainty that can disrupt fuel markets, undermine compliance planning, and create volatility for producers and consumers alike.

Taken together, these provisions will help enhance fuel supply, promote competition, and help lower costs for American families, while providing needed certainty to farmers, refiners, ethanol producers, and fuel retailers. At a time when consumers are acutely sensitive to energy prices, this amendment represents a pragmatic solution that balances energy affordability, rural economic strength, and regulatory certainty.

We respectfully urge you to support this bipartisan Farm Bill amendment, encourage its inclusion as the legislation advances, and support final passage of the Farm Bill on the House floor. We stand ready to work with you to support policies that promote consumer
choice, economic stability, and a reliable fuel supply for the nation.

Thank you for your consideration and for your continued leadership on these important issues.

The post Broad Coalition Urges Congress to Advance Year-Round E15 in Farm Bill appeared first on Growth Energy.

We write today to provide comments regarding the prevailing wage and apprenticeship (PWA)
requirements set forth in T.D. 9998,1 as applied to the Section 45Z Clean Fuel Production Credit, and the
Treas. Reg. §1.45Z-3 regulation that further define the PWA requirements under section 45Z. Since the
publication of these final rules on June 25, 2024, the companies we represent have been diligently
attempting to comply with their provisions. We strongly support the objectives of Treas. Reg. §1.45Z;
however, our members’ efforts to apply this regulation to our businesses to claim the enhanced section
45Z credit have raised a number of issues. We have the following concerns regarding application of the
PWA rules in the 45Z context, and we are hopeful you will consider addressing them.
I. PWA Rules for Facilities in Construction Prior to the Inflation Reduction Act (IRA)
Taxpayers have faced substantial uncertainty regarding how to manage the PWA rules for section 45Z
purposessince their original enactment in the Inflation Reduction Act of 2022 (IRA). The original transition
rules set forth in subsections 45Z(f)(6) and (f)(7) were wholly prospective in nature and addressed only
the application of the PWA rules for projects placed in service after the January 1, 2025,2 effective date
for section 45Z. This created significant problems and inequity for projects that started construction
before the enactment of the PWA rules under the IRA and placed in service after December 31, 2024.
After the enactment of the IRA and the PWA rules, the only guidance taxpayers had to rely on in managing
PWA was set forth in Notice 2022-61. Taxpayers logically assumed this guidance would ultimately be
extended for section 45Z purposes. In particular, taxpayers assumed that a single unified approach to
grandfathering projects from the scope of PWA would ultimately apply for all IRA credits.3
Due to the
absence of meaningful and actionable PWA guidance for section 45Z, taxpayers were unable to develop practical approaches to addressing PWA for facilities already well into construction before these rules
were enacted.
The promulgation of the final PWA regulationsin June 2024 wasthe first time taxpayers were made aware
that construction delays could cause a facility to become subject to PWA requirements. The following
example illustrates this outcome:
Taxpayer X commenced development of a biofuels production facility prior to the
enactment of the IRA. Due to natural disasters, fires or other unavoidable construction
delays, the facility was placed in service on August 1, 2025. Based on the plain language
of section 45Z(f)(6) and (f)(7) and Treas. Reg. § 1.45Z-3, the facility would be required to
obtain PWA information for the construction period between 2023 and August 1, 2025,
in addition to being subject to penalties and interest for lack thereof.
This example highlights the unduly burdensome application of the PWA rules under section 45Z(f)(6) and
(f)(7) and Treas. Reg. § 1.45Z-3. Although Treas. Reg. § 1.45Z-3 attempts to provide a limited transition
period for PWA during the construction period,4 it failed to address the common instance of facilities for
which construction began prior to the existence of the PWA rules and to the PWA grandfathering date set
forth in Notice 2022-61. As a result, taxpayers would be unfairly subject to penalties and interest for
noncompliance with a law that was not, under the IRS’s own guidance, applicable to pre-IRA construction
periods with respect to all other tax credits.
There is no indication that Congress anticipated, or intended, such an outcome. Notice 2022-61 was
consistent with congressional intent and established a clear, workable, and administrable bright-line rule
for determining the application of PWA requirements for other IRA credits. By contrast, the retroactive
and inflexible application of the PWA rules in the section 45Z context does not further that intent.
We acknowledge that the statutory transitional rules in sections 45Z(f)(6) and (f)(7) expressly reference
the placed-in-service date as determinative of PWA applicability for section 45Z purposes. Nevertheless,
equitable relief is warranted for taxpayers that have taken timely and affirmative steps to address
technical PWA noncompliance for projects such as the one described above.
Requested Solution: We are seeking equitable relief for projects that began construction prior to January
29, 2023, but were not placed-in-service until after December 31, 2024. This equitable relief could take
several forms, including but not limited to: (i) sub-regulatory guidance such as an IRS Notice5 offering
targeted relief to taxpayers seeking to bring these projects into a PWA compliant status to claim the
maximum allowable 45Z PTC; (ii) an industry directive; or (iii) a voluntary amnesty program with predefined rules of the road for taxpayers willing to take the appropriate steps to bring these projects into
PWA compliant status.
This request should take into account the following factors:(1) Retroactive remediation of PWA compliance across multiple, unrelated construction service
providers over a multi-year period is impracticable, and in most cases, unworkable. If Treasury
determines that some degree of retroactive remediation is necessary, such remediation should
be narrowly scoped, timelimited, and subject to a reasonable, goodfaith compliance standard.
At a minimum, remediation should not be required for work subject to PWA that occurred
prior to January 1, 2025.
(2) Retroactive application of the apprenticeship requirements under section 45(b)(8) would only
require taxpayers to pay significant penalty payments without any real enhancements to
apprenticeship programs across the energy industry. This is not the intent of the law nor the
intent of Congress. Taxpayers should not be subject to these penalties when they did not have
the opportunity to adhere to these rules in a timely manner; and
(3) Taxpayers that have shown a good faith effort to comply with PWA for projects that were not
placed in service by January 1, 2025, should not be subject to penalties and interest. The IRS
should issue guidance to support a mechanism that helps taxpayers who have been clearly
disadvantaged by these rules. Taxpayersshould not be subject to penalties and interest for failing
to follow rules that did not exist when they began their construction activities.
We respectfully urge Treasury and the IRS to develop equitable relief in whatever form deemed most
appropriate so taxpayers may meet the 2025 tax return filing requirements.
II. Other Dates of Applicability Issues
A. Although subsections 45Z(f)(6)(B)(i) and (ii) excuse facilities placed in service prior to 2025 from
compliance with PWA requirements with respect to construction, such facilities are not excused from
ongoing compliance with respect to alterations or repairs performed after 2024. In Treas. Reg. §
1.45Z-3(b)(2), Treasury has followed the statute by requiring continued compliance with PW
requirements for alterations and repairs even for facilities placed in service prior to 2025. The
regulation does not reflect, however, the statement made in the Preamble of T.D. 9998, that Treasury
interprets the PWA requirements as applying only to facilities placed in service after 2021:
Undersection 13010(k) of the IRA, the rules ofsection 45(b)(7) and 45(b)(8) apply with
respect to facilities that are placed in service after December 31, 2021. Thus, the
Treasury Department and the IRS interpret the PWA requirements of sections
45Z(f)(6) and 45Z(f)(7) generally as applying to any qualified facility that is placed in
service after December 31, 2021, subject to the transition rule described in Section II.
of this Summary of Comments and Explanation of Revisions. (Summary of Comments
and Explanation of Revisions, Section IX.G.) (Emphasis added.)
The implication of thisstatement isthat the PWA requirements do not apply at all to any clean fuel facility
placed in service before 2022. On its face, however, Treas. Reg. § 1.45Z-3(b)(2) simply provides that any
facility placed in service before 2025 must comply with the requirements for alterations and repairs,
thereby including even facilities placed in service before 2022.
Understandably, without confirmation that the preamble statement may be relied upon to relieve
taxpayers of PW compliance as to alterations and repairs of facilities placed in service before 2022,
taxpayers that are using older facilities to produce clean fuel are confronted with an ambiguity as towhether they are obligated to comply with PW with regard to alterations and repairs since the regulation
is inconsistent with the Preamble statement.
Requested Solution: We request guidance clarifying that facilities placed in service prior to 2022 are not
subject to PW compliance with respect to alterations and repairs.
B. Additionally, the statutory language of the IRA and the final PWA rules raise an ambiguity
regarding the applicability of PWA compliance for section 45Z. The IRA provides that the PWA
requirements apply to section 45Z “with respect to any taxable year beginning after December 31,
2024, for which the credit is allowed under this section.” (Emphasis added.) (P.L. 117-169, Aug. 16,
2022, Section 13704(a)). This bolded language could be taken to mean that PWA compliance as to
alterations and repairs is required only in years for which the 45Z enhanced credit is claimed.6
However, in the final PWA guidance applicable to 45Z, Section 1.45Z-3(b)(2) simply states that a qualified
facility placed in service prior to January 1, 2025, is one “that meets the prevailing wage requirements of
section 45(b)(7) and § 1.45-7 with respect to any alteration or repair of such qualified facility that is
performed in taxable years beginning after December 31, 2024,” implying that PWA compliance is
required for all years beginning with 2025, regardless of whether the enhanced credit is claimed.
Requested Solution: We request that the Treasury Department provide additional guidance with respect
to the PWA rules to clarify that PW compliance for alterations and repairs is required only for those years
for which the enhanced 45Z credit is claimed.
III. Definition of Alteration or Repair
Since the release of the final PWA regulations, taxpayers continue to experience frustration with the
definitions of “alteration or repair” included in the final PWA rules. For instance, many taxpayers believe
that the current definition of maintenance isso narrow that almost every activity is classified as a “repair.”
For taxpayers in the clean fuel industry, certainty as to whether an activity is a repair or maintenance is
crucial as failure to comply with the applicable requirements for repairs will prevent taxpayers from
accessing the full credit amount.
For example, clean fuel production plants are extremely complicated and involve a number of parts
subject to routine wear. A production plant must be actively maintained on both a daily and routine basis
and many parts are subject to periodic replacement protocols. For example, many parts have a commonly
accepted useful life but are generally only replaced when they fail to avoid incurring the significant waste
and capital cost of procuring replacement parts before they are necessary.
Requested Solution: We request that the Treasury Department continue to work with taxpayersto further
refine the definition of “alteration or repair,” particularly as distinguished from “maintenance.” There are
several ways to do this, all of which could be handled in a Revenue Procedure:
(1) Provide additional examples of maintenance and “alteration or repair.”
(2) Clarify that taxpayers may demonstrate that tasks are properly treated as “maintenance” by
reference to written materials provided by an equipment manufacturer.(3) Clarify that “maintenance” istreated as amountsthat would not be capitalized to the qualified
facility and “repair or alteration” includes only costs that may be capitalized to the qualified
facility, in each case, under existing U.S. federal income tax capitalization requirements.
(4) Provide a de minimis threshold for the cost of labor or number of hours of labor required per
task. This could correlate with the $2,000 contract applicability threshold from Davis-Bacon that
is intended to apply in the context of 45Z PWA requirements. In other words, if the labor
associated with a task would cost lessthan $2,000 at a service provider’stypical rate (or the wages
typically paid by the taxpayer to its employees for similar work), then the task is not treated as
“repair or alteration.”
IV. Prevailing Wage
“Prevailing Wage” in 45Z relies on Davis-Bacon Act wage determinations issued by the Department of
Labor for the “locality” in which the facility is located, which means that a taxpayer must pay the wages
set by DOL under general wage determinations for a geographic area. However, the unique geography of
biofuels production and the relative novelty of the technology create situations where the DOL has
insufficient data to issue a prevailing wage determination in some counties where these facilities are
located.
While current IRS regulations provide a mechanism to request “supplemental wage determinations” or
“additional classifications and rates for those localities or specific types of labor,” that process creates
additional burdens and delays for the taxpayer.
Requested Solution: We request that taxpayers claiming the 45Z credit be permitted to use the relevant
prevailing wage determination or labor classification from the nearest locality (defined as any locality
adjacent to or sharing a border with the subject locality) if that information is not available for the locality
where the facility is located.
V. Compliance Testing
A. While periodic reviews are important and necessary to ensure and demonstrate compliance with
the PWA requirements, pursuant to regulation 1.45-7(c)(3)(iii)(B), taxpayers find themselves
compelled to perform burdensome current quarterly reviews.
Requested Solution: We request that additional guidance for the PWA rules instead allow for annual
reviews for compliance.
B. Frequently, work undertaken to effect an “alteration or repair” is performed by a contractor
rather than directly by the taxpayer. Notwithstanding any contractual agreement requiring the
contractor to provide the necessary payroll data to allow the taxpayer to meet PWA compliance
record-keeping requirements, many of these actors are small companiesthat may go into bankruptcy,
refuse to provide information for various reasons (including concerns about personally identifiable
information (PII)), or simply disappear.
Requested Solution: We request that the additional guidance for the PWA rules allow the taxpayer to rely
on an affidavit provided by the contractor affirming its compliance and permit such affidavit to satisfy the
taxpayer’s compliance obligation. We also request that a good faith exception apply in cases where the
taxpayer has attempted multiple times without success to reach an unresponsive or uncooperative
contractor and has been unable to procure the data required or an affidavit of compliance.VI. Penalty Abatement
Taxpayers often find themselves in the position of having underpaid by extremely small amounts.
However, in addition to being required to cure the underpayment, they are also potentially subject to a
$5,000 penalty multiplied by the total number of workers who were paid wages below the prevailing rate
(section 45(b)(7)(B)(i)(II)), regardless of how small the required corrective payment might be. While
regulation 1.45-7(c)(6)(i) provides a penalty waiver under certain circumstances, the amount of time
provided to the facility owner to correct the underpayment (1 month) is very restrictive, particularly if the
quarter in question happens to be the final quarter of the year.
Requested Solution: We request that any additional guidance for the PWA rules create a safe harbor de
minimis dollar amount beneath which no penalty isincurred for underpayment. In addition, development
of a de minimis amount of failure to comply, under which no cure payment is required, would be helpful
in cases for which information is not available to allow for the corrective payment to the affected worker.
Finally, we ask that taxpayers be provided 90 days beyond the end of the quarter in question to make
corrective payments.
Conclusion
Thank you for all the hard work you have put into the further implementation of the IRA and OBBBA and
for your commitment to ensuring the clean energy provisions work as intended. We hope that you will
consider the above requests for guidance in the spirit in which they are offered, and that is to make these
rules more administrable and workable for both industry and government. We encourage you to reach
out to any of the undersigned as a resource on these issues.
Sincerely,
Advanced Biofuels Association
Alternative Fuels & Chemicals Coalition
American Biogas Council
American Petroleum Institute
Clean Fuels Alliance America
Fuel Cell and Hydrogen Energy Association
Growth Energy
Methanol Institute
Renewable Fuels Association
RNG Coalition
SAF Coalition

The post Growth Energy Joins Letter Urging Clarity in Prevailing Wage 45Z Provisions appeared first on Growth Energy.

American farmers deeply appreciate the Trump Administration’s actions to support farmers during an incredibly tenuous time for American agriculture. Actions like the recent Farmer Bridge Assistance Program have provided a crucial opportunity for a return on the 2025 crop, but unfortunately, the outlook for 2026 returns to negative margins. Farmers are facing structural economic issues where projected costs exceed expected revenues. As you know, biofuels are a critical market for American farmers, and tax incentives like the 45Z tax credit are essential policy instruments to secure long-term demand for liquid fuels made from American-grown feedstock. Stable, long-term market incentives will help farmers outpace their global competitors, and allow them to make capital, input, and management decisions that shape the next several growing seasons.

This Administration has committed to putting farmers first and to securing the future of liquid fuels. Ensuring that farmers can reap the potential market benefits of the 45Z tax credit comes at a critical time for farmers across the country.

For 45Z to function as it should, three actions are urgently needed. First, USDA’s updated guidance and carbon intensity (CI) calculator must be transmitted to and processed through OMB. Next, the Department of Energy (DOE) needs to include USDA’s updated CI calculator (FD-CIC) in the updated 45Z-CF GREET model. Finally, Treasury must adopt guidance to formally recognize the ability of verified on-farm practices to lower CI scores in a way that does not distort planting decisions. To maximize farmer participation and ensure the program’s success—without disrupting the nation’s highly efficient grain markets and logistics—Treasury should incorporate book-and-claim alongside mass-balance supply-chain traceability systems. Without this regulatory clarity, farmers, biofuel producers, and lenders may lack the certainty required to invest and participate at scale.

Agricultural conservation practices, such as use of cover crops and no-till or strip-till, improve soil structure and organic matter, increase water infiltration, and enhance drought tolerance. These outcomes reduce crop damage during periods of excessive precipitation while also stabilizing yields under drought stress ultimately lowering risk and reducing indemnity payments. 45Z can serve as a catalyst for creating an environment that enables these practices to scale.

45Z also contributes to economic stability. Adoption of regenerative agricultural practices, which has been emphasized by President Trump’s Cabinet, have increased cost implications. Farmers often must make significant capital investments in equipment, absorb variable costs such as cover crop seed, and undertake significant management changes. Especially in a distressed farm economy, these investments are not practical without a predictable and bankable return. Clear 45Z guidance is critical for farmers and their lenders to plan with confidence. Without regulatory certainty on the inclusion of on-farm practices, those incentives will not materialize at the scale necessary to drive participation.

Finally, the precedent set by formally incorporating on-farm practice-based CI reductions into 45Z will shape future market opportunities well beyond liquid fuels. As row crop commodities increasingly serve as bio-feedstocks for bio-plastics, bio-textiles, and bio-chemicals, this guidance can serve as a durable framework for farmers to expand their income streams. Leveraging an optimized 45Z as a model could unlock new domestic markets for U.S. farmers while accelerating the transition to a healthier food, fuel, and fiber system.

We respectfully urge USDA, DOE, Treasury, and the White House to complete the remaining regulatory steps necessary to operationalize 45Z so that farmers can participate effectively. Timely, durable guidance is essential to provide farmers, biofuel producers, and lenders with the certainty needed to invest, innovate, and deliver on the Administration’s stated goals for soil health, market expansion, and farm profitability.

Sincerely,

National Corn Growers Association
American Soybean Association
National Sorghum Producers Association
Renewable Fuels Association
Growth Energy
National Oilseed Processors Association
Clean Fuels Alliance America
The SAF Coalition
Alabama Soybean and Corn Association
Illinois Corn Growers Association
Indiana Corn Growers Association
Iowa Corn Growers Association
Kansas Corn Growers Association
Kentucky Corn Growers Association
Michigan Corn Growers Association
Minnesota Corn Growers Association
Missouri Corn Growers Association
Nebraska Corn Growers Association
North Dakota Corn Growers Association
Ohio Corn and Wheat Growers Association
South Dakota Corn Growers Association
Tennessee Corn Growers Association
Texas Corn Producers Association
Virginia Grain Producers Association
Wisconsin Corn Growers Association
Texas Grain Sorghum Association
New Mexico Sorghum Producers
Nebraska Sorghum Producers

The post Growth Energy Joins Letter Advocating for Farm Practices in 45Z appeared first on Growth Energy.

Dear Ambassador Greer,

On behalf of the undersigned associations and organizations, we commend you and your team for running a transparent and inclusive hearing last fall ahead of this year’s 2026 review of the United States-Mexico-Canada Agreement (USMCA).

At the hearing, officials heard unanimous agreement on the significance of USMCA’s rules-based framework and how critical the agreement is to U.S. competitiveness and export success. This broad-based support was underscored in a December 1, 2025, letter to you from more than 500 U.S. national, state, and local organizations.

Reflecting this broad consensus, we write to convey our strong support for extending USMCA and urge USTR’s sustained and meaningful engagement with U.S. business, manufacturing, and agricultural stakeholders throughout the review and until the agreement is renewed for a full 16-year term.

We share the Administration’s objective of a more secure, resilient, and prosperous United States. As the United States’ largest export markets and primary sources of indispensable inputs, Mexico and Canada are foundational to our economic strength and resilience. Consequently, modifications to USMCA’s rules or substantive new proposals have the potential to reshape American competitiveness at home and abroad.

U.S. production and supply chains are built on trillions in long-term investment, which have been refined over years to be highly efficient to comply with USMCA’s rigorous framework. Material changes to USMCA requirements or rules of origin could lead to multi-year supply chain disruptions at significant cost to companies invested in America, raise consumer prices, and erode North American
competitiveness. It is therefore imperative that proposals, including rules of origin, be clear, implementable, recognize manufacturing and production realities, and minimize trade disruptions.

To this end, we respectfully request structured, substantive, and ongoing engagement with U.S. business, manufacturing, and agricultural stakeholders on any proposals.

We stand ready to work constructively with USTR toward a positive outcome that extends the USMCA, ensures the agreement’s full implementation, resolves irritants, and restores the predictability and certainty in North American trade that will enable businesses to accelerate their long-term supply chain and investment decisions while avoiding undue cost pressures.

We strongly support concurrent efforts to resolve tariff and non-tariff barriers and to ensure existing USMCA commitments are fully implemented and adhered to. Maintaining duty-free treatment for USMCA-compliant goods throughout this process is an indispensable prerequisite for North American stability. To strengthen the U.S. manufacturing and industrial base, we urge the Administration to avoid imposing any new duties on Canada or Mexico and to restore duty-free trade.

We remain committed to strengthening these vital North American partnerships, committed to this process, and committed to a renewed and truly trilateral USMCA.

Sincerely,
ACT | The App Association
Alliance for Automotive Innovation
American Apparel & Footwear Association
American Automotive Policy Council
American Clean Power Association
American Coalition for Ethanol
American Council of Life Insurers
American Feed Industry Association
American International Automobile Dealers Association
American Pet Products Association
American Petroleum Institute
American Seed Trade Association
American Soybean Association
American Sportfishing Association
American Truck Dealers
Animal Health Institute
Associated Equipment Distributors
Association of Equipment Manufacturers
Auto Care Association
Autos Drive America
Business Software Alliance
Can Manufacturers Institute
Canadian American Business Council
Coalition for North American Trade
Coalition of Services Industries
Computer & Communications Industry Association
Consumer Technology Association
Corn Refiners Association
CropLife America
Distilled Spirits Council of the U.S.
Fresh Produce Association of the Americas
Global Business Alliance
Global Data Alliance
Global Innovation Forum
Growth Energy
Information Technology Industry Council
MEMA. The Vehicle Suppliers Association
National Automobile Dealers Association
National Barley Growers Association
National Confectioners Association
National Corn Growers Association
National Council of Farmer Cooperatives
National Electrical Manufacturers Association
National Fisheries Institute
National Foreign Trade Council
National Oilseed Processors Association
National Pork Producers Council
National Retail Federation
National Sunflower Association
North American Export Grain Association
North American Millers’ Association
Outdoor Industry Association
Pet Food Institute
Performance Racing Industry
Renewable Fuels Association
Retail Industry Leaders Association
Semiconductor Industry Association
SNAC International
Software & Information Industry Association
Specialty Equipment Market Association
Technology Trade Regulation Alliance
Telecommunications Industry Association
U.S. Apple Association
U.S. Chamber of Commerce
US Council for International Business
USA Poultry & Egg Export Council
USA Pulses
USA Pulses Trade Association
USA Rice

The post Growth Energy Joins Coalition Letter on USMCA appeared first on Growth Energy.

Dear Mr. President:
We write on behalf of organizations representing ethanol producers, oil refiners, fuel
marketers, travel plazas, truck stops, and convenience store retailers to express the need
for long-term policy certainty across the transportation fuel sector. Our diverse group of
industries often have unique policy priorities and market concerns, but we have always
shared a common goal to provide affordable, reliable liquid fuels for consumers. However,
our collective ability to continue to do so is being threatened by the ongoing uncertainty
regarding the sale of year-round E15 and the administration of Small Refinery Exemptions
(SREs) under the Renewable Fuel Standard (RFS) program.
E15 continues to play an expanding role in the fuel marketplace, but unpredictable shortterm waivers, seasonal and geographic restrictions, and regionally unique summer
gasoline specifications in the Midwest have created a shifting regulatory environment that
complicates planning and investment. Legislation allowing the year-round, nationwide
sale of E15 would improve fungibility and substantially reduce many of the complexities
that arise for our industries as we operate in a national marketplace.
In addition, we believe Congress must take legislative action to reform the Small Refinery
Exemption program. The current SRE structure has encouraged a system of winners and
losers that distorts the marketplace, creates instability, and ultimately, hurts consumers.
A more consistent and narrowly applied SRE structure would create a far more predictable
regulatory environment.
The absence of nationwide E15 and the administration of the SRE program present varying
challenges for our industries. They both impact investment and compliance planning,
blending decisions, and the stability of national fuel supply chains. Addressing these two
issues through clear legislation would provide a more coherent and durable policy
foundation, reduce volatility, and enhance confidence for all participants in the
transportation fuel sector.
For these reasons, we respectfully urge you to support legislation that brings lasting
certainty to these fuels issues and supports a stable, efficient marketplace.
Thank you for your consideration of these matters. Our organizations remain committed to
supporting constructive solutions as Congress evaluates next steps.
Sincerely,
American Petroleum Institute
Growth Energy
National Association of Convenience
Stores
NATSO, Representing America’s Travel
Centers and Truck Stops
Renewable Fuels Association
SIGMA: America’s Leading Fuel Marketers
CC:
The Honorable Mike Johnson
Speaker, U.S. House of Representatives
The Honorable Hakeem Jeffries
Minority Leader, U.S. House of
Representatives
The Honorable John Thune
Majority Leader, U.S. Senate
The Honorable Chuck Schumer
Minority Leader, U.S. Senate
The Honorable Doug Burgum
Secretary, U.S. Department of the Interior
The Honorable Brooke Rollins
Secretary, U.S. Department of Agriculture
The Honorable Chris Wright
Secretary, U.S. Department of Energy
The Honorable Lee Zeldin
Secretary, U.S. Environmental Protection
Agency

December 4, 2025
President Donald J. Trump
The White House
1600 Pennsylvania Avenue, NW
Washington, DC 20500

Re: E15 Negotiations

The post Industry Letter to White House on E15 Negotiations appeared first on Growth Energy.