Petition for Writ of Certiorari — Valero Energy Corporation, et al., Petitioners v. Environmental Protection Agency

Supreme Court briefDec 30, 2019

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APPENDIX

1a

APPENDIX A

UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT

————

No. 16-1052

————

Consolidated with 16-1055, 17-1255, 17-1259,

18-1021, 18-1024, 18-1025, 18-1029

————

ALON REFINING KROTZ SPRINGS, INC.,

Petitioner,

v.

ENVIRONMENTAL PROTECTION AGENCY,

Respondent,

MONROE ENERGY, LLC, et al.,

Intervenors.

————

On Petitions for Review of Agency Action of the

United States Environmental Protection Agency

————

Argued October 5, 2018

Decided August 30, 2019

————

Samara L. Kline argued the cause for petitioners.

With her on the briefs were Evan A. Young, Megan H.

Berge, Lisa M. Jaeger, Brittany M. Pemberton, Clara

Poffenberger, Richard S. Moskowitz, Robert J. Meyers,

Thomas A. Lorenzen, Elizabeth B. Dawson, Warren R.

Neufeld, LeAnn M. Johnson, and Jonathan G. Hardin.

Albert M. Ferlo Jr. and Krista Hughes entered

appearances.

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Meghan E. Greenfield, Trial Attorney, U.S. Department of Justice, argued the cause for respondent. With

her on the brief was Jeffrey H. Wood, Acting Assistant

Attorney General. Daniel R. Dertke, Attorney, entered

an appearance.

Robert A. Long Jr. argued the cause for intervenors

American Petroleum Institute and Growth Energy.

With him on the brief were Kevin King, Seth P.

Waxman, David M. Lehn, Saurabh Sanghvi, and

Claire Chung. Stacy R. Linden entered an appearance.

Shannen W. Coffin and Linda C. Bailey were on the

brief for amici curiae NACS, et al. in support of

respondent EPA.

————

No. 17-1044

————

Consolidated with 17-1045, 17-1047, 17-1049,

17-1051, 17-1052

————

COFFEYVILLE RESOURCES REFINING & MARKETING,

LLC AND WYNNEWOOD REFINING COMPANY, LLC,

v.

Petitioners,

ENVIRONMENTAL PROTECTION AGENCY,

Respondent,

ALON REFINING KROTZ SPRINGS, INC., et al.,

Intervenors.

————

On Petitions for Review of Action of the United

States Environmental Protection Agency

————

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Brian Killian argued the cause for petitioner The

National Biodiesel Board. With him on the briefs was

Douglas A. Hastings.

Samara L. Kline and Thomas Allen Lorenzen,

argued the causes for Obligated Party Petitioners.

With them on the briefs were Evan A. Young, Lisa M.

Jaeger, Brittany M. Pemberton, Clara Poffenberger,

Richard S. Moskowtiz, Robert J. Meyers, Elizabeth B.

Dawson, David W. DeBruin, Thomas J. Perrelli,

Matthew E. Price, LeAnn M. Johnson, and Jonathan G.

Hardin. David Y. Chung, Eric D. Miller, and Albert M.

Ferlo Jr. entered appearances.

Patrick R. Jacobi and Samara M Spence, Attorneys,

U.S. Department of Justice, argued the causes for

respondent. With them on the brief was Jeffrey H.

Wood, Acting Assistant Attorney General.

Thomas Allen Lorenzen argued the cause for intervenors American Fuel & Petrochemical Manufacturers

and American Petroleum Institute in support of

respondent regarding Biomass-Based Diesel Issues.

With him on the brief were Robert J. Meyers, Elizabeth

B. Dawson, Richard S. Moskowitz, Robert A. Long, Jr.,

and Kevin King. Stacy R. Linden entered an appearance.

Robert A. Long, Jr., Kevin King, Bryan M. Killian,

Douglas A. Hastings, Seth P. Waxman, David M. Lehn,

Saurabh Sanghvi, and Claire H. Chung were on the

brief for intervenors Growth Energy, et al. in support

of respondent. Eric D. Miller entered an appearance.

Before: PILLARD and KATSAS, Circuit Judges, and

WILLIAMS, Senior Circuit Judge.

Opinion for the Court filed PER CURIAM.

Opinion concurring in part and concurring in the

judgment filed by Senior Circuit Judge WILLIAMS.

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TABLE OF CONTENTS

I. Introduction ..................................................... 6 [5a]

II. Background ..................................................... 7 [6a]

A. Legal Background ...................................... 7 [6a]

B. Procedural Background ......................... 12 [11a]

1. 2007, 2010, and 2017 Point of

Obligation Proceedings .................... 12 [11a]

2. 2017 Annual Volumetric Proceedings .................................................... 15 [14a]

III. Standard of Review ................................... 17 [16a]

IV. 2010 Point of Obligation Rule ................... 17 [17a]

A. Jurisdiction ............................................ 17 [17a]

1. Final Agency Action Under Section

7607(b)(1) .......................................... 19 [19a]

2. After-Arising Grounds Under Section

7607(b)(1) .......................................... 28 [28a]

3. Mandatory Reconsideration Under

Section 7607(d)(7)(B) ........................ 29 [29a]

B. Merits of Challenges to EPA’s Refusal

to Revise the 2010 Point of Obligation

Rule ........................................................ 32 [32a]

V. 2017 Annual Volumetric Rule .................... 41 [42a]

A. Point of Obligation ................................. 42 [42a]

1. Jurisdiction ....................................... 42 [43a]

2. Merits ................................................ 43 [44a]

B. Cellulosic Biofuel Projection.................. 53 [55a]

C. Cellulosic Waiver ................................... 58 [60a]

VI. 2018 Volume for Biomass-Based Diesel ... 62 [64a]

A. NBB’s Standing...................................... 63 [65a]

B. Merits of NBB’s Challenges .................. 65 [67a]

VII. Conclusion ................................................. 70 [72a]

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PER CURIAM:

I. Introduction

The Clean Air Act requires EPA to publish “renewable fuel standards,” ultimately expressed as “applicable

percentages,” each year to ensure that the total supply

of transportation fuel sold or imported into the United

States contains specified proportions of each of four

categories of renewable fuels. Congress intended the

Renewable Fuel Standards (RFS) program to “move

the United States toward greater energy independence and security” and “increase the production of

clean renewable fuels.” See Energy Independence and

Security Act of 2007 (EISA), Pub. L. No. 110-140,

preamble, 121 Stat. 1492 (2007) (codified at 42 U.S.C.

§ 7545(o)).

In these related cases, Alon Refining Krotz Springs,

together with other petroleum refineries and their

trade associations—the “Alon Petitioners”—seek review

of EPA’s decision not to revise its 2010 point of obligation regulation requiring refineries and importers, but

not blenders, to bear the direct compliance obligation

of ensuring that transportation fuels sold or introduced into the U.S. market include the requisite

percentages of renewables. Coffeyville Resources Refining & Marketing and another group of refineries and

trade associations—the “Coffeyville Petitioners”—

challenge EPA’s refusal to reassess the appropriateness of the point of obligation in the context of its 2017

annual volumetric rule, which set the 2017 applicable

percentages for all four categories of renewable fuel

and the 2018 applicable volume for one subset of such

fuel, biomass-based diesel. See 81 Fed. Reg. 89,746

(Dec. 12, 2016) (2017 Rule). The Coffeyville Petitioners

also contend that EPA arbitrarily set the 2017 percentage standards too high. The National Biodiesel

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Board (NBB)—a biomass-based diesel industry trade

association—separately contends that EPA set the

2018 applicable volume for biomass-based diesel too

low. Various trade associations representing refineries

and producers of renewable fuels have intervened in

support of EPA. For the reasons that follow, we deny

each of the petitions for review, many of which recycle

arguments raised and rejected in prior challenges.

II. Background

A. Legal Background

Congress established the RFS program in 2005 as

part of the Energy Policy Act, Pub. L. No. 109-58, 119

Stat. 594 (2005) (as amended at 42 U.S.C. § 7545(o)).

The statute mandates the gradual introduction of four

nested categories of renewable fuels into the United

States’ supply of gasoline, diesel, and other transportation fuels. See 42 U.S.C. § 7545(o)(2)(B). These

categories include: (1) total renewable fuel; (2) advanced

biofuel; (3) cellulosic biofuel; and (4) biomass-based

diesel. Id. § 7545(o)(2)(A)(i), (B). The umbrella category, total renewable fuel, covers the three other

categories plus any conventional renewable fuels, such

as corn-based ethanol. See id. § 7545(o)(1)(F), (J),

(2)(A)(i). The advanced biofuel subset includes any

renewable fuel (except ethanol from cornstarch) that

has at least 50% lower lifecycle greenhouse gas

emissions than fossil fuels. Id. § 7545(o)(1)(B). The

statute further specifies two nonexclusive subsets of

advanced biofuels: cellulosic biofuel (a renewable fuel

derived from cellulose materials such as corn stalks

and husks) and biomass-based diesel (a diesel fuel

substitute made from feedstocks such as animal fats).

Id. § 7545(o)(1)(B), (D), (E); EPA Coffeyville Br. 4-5.

The following figure depicts the nested nature of the

four fuel categories.

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Source: Coffeyville Br. 11.

Four tables in the statute set forth gradually

increasing annual “applicable volume” requirements

for each category of renewable fuel. See 42 U.S.C.

§ 7545(o)(2)(B)(i). The statute sets applicable

volumes for biomass-based diesel through 2012, id.

§ 7545(o)(2)(B)(i)(IV), and applicable volumes for

the other three categories through 2022, id.

§ 7545(o)(2)(B)(i)(I)—(III). Under those tables, as the

total quantities of renewable fuel rise over time, the

ratio of advanced biofuels relative to conventional

renewable fuel gradually increases. Id. For compliance

years (which match calendar years) after those specified

in the tables, the statute requires EPA, in coordination

with the Secretaries of Energy and Agriculture, to set

the annual applicable volumes based on a review of the

implementation of the program plus an analysis of six

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listed factors. Id. § 7545(o)(2)(B)(ii). For years not

specified in the table, EPA must publish the applicable

volumes fourteen months before the year in which

they will apply—volumes that, shortly before the

start of the compliance year, EPA translates into

percentage standards. Id.

Various “waiver” provisions require or permit EPA

to lower the annual applicable volumes. Two are

relevant for the purposes of this case. First, under the

“cellulosic waiver provision,” EPA must make its

own projection of the volume of cellulosic biofuel

that will be produced in the following year. Id.

§ 7545(o)(7)(D)(i). If that projection is less than the

statutory figure, the agency must use its own projection as the applicable volume of cellulosic biofuel. Id.;

see Am. Petroleum Inst. v. EPA, 706 F.3d 474, 477-80

(D.C. Cir. 2013) (API). The same cellulosic waiver

provision authorizes (but does not require) EPA to

also reduce the advanced biofuel and total renewable

biofuel volume requirements “by the same or a lesser

volume” as the cellulosic biofuel reduction, 42 U.S.C.

§ 7545(o)(7)(D)(i), and EPA has “broad discretion”

regarding whether and how to do that, Monroe Energy,

LLC v. EPA, 750 F.3d 909, 915 (D.C. Cir. 2014).

Separately, under the “general waiver provision,” EPA

may reduce any of the statutory applicable volumes if

it determines “that implementation . . . would severely

harm the economy or environment,” or “that there

is an inadequate domestic supply.” 42 U.S.C.

§ 7545(o)(7)(A); see Ams. for Clean Energy v. EPA, 864

F.3d 691, 707-13 (D.C. Cir. 2017) (ACE).

After EPA determines the waiver-adjusted applicable volumes, it must translate those volumes into

“renewable volume obligation[s]” for each category of

renewable fuel for the upcoming compliance year.

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42 U.S.C. § 7545(o)(3)(B)(i). The volume obligation for

each category of renewable fuel is expressed as an

“applicable percentage,” also known as a “percentage

standard,” calculated by dividing the adjusted applicable volume for that category of fuel by the total

anticipated volume of non-renewable transportation

fuel that will be introduced into commerce (which EPA

derives based on an estimate provided by the Energy

Information Administration) in the coming compliance

year. Id. § 7545(o)(3)(A), (B)(ii)(II); 40 C.F.R. § 80.1405(c).

The statute calls on EPA to publish the percentage

standards not later than November 30—a month

before the start of the compliance year. 42 U.S.C.

§ 7545(o)(3)(B)(i).

EPA must place the renewable volume obligations

on “refineries, blenders, and importers, as appropriate.” 42 U.S.C. § 7545(o)(3)(B)(ii)(I); see also id.

§ 7545(o)(2)(A) (requiring EPA to promulgate implementing regulations, including “compliance provisions

applicable to refineries, blenders, distributors, and

importers, as appropriate,” designed to ensure that

transportation fuel sold or introduced into the United

States “contains at least” the required annual applicable volumes). The entities that EPA designates to

meet the volume obligations are known as “obligated

parties.” Monroe Energy, 750 F.3d at 912. Each

obligated party must ensure that the volume of nonrenewable fuel it sells or introduces into U.S. commerce

is matched by selling or introducing a corresponding

volume of each category of renewable fuel at the level

EPA’s percentage standard requires for that category.

See ACE, 864 F.3d at 699. The percentage standards

are set in the anticipation that, if each obligated party

meets them and EPA’s projection regarding the country’s

total transportation fuel supply bears out, the amount

of each category of renewable fuel introduced into the

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economy in the upcoming compliance year will equal

the applicable volumes for that year. Id. Obligated

parties bear no direct responsibility for any shortfalls

in the applicable volumes so long as they comply with

the percentage standards.

EPA assigns a set of “renewable identification

numbers” (RINs) to each batch of renewable fuel that

is produced or imported for use in the United States.

40 C.F.R. § 80.1426; see 42 U.S.C. § 7545(o)(5); Monroe

Energy, 750 F.3d at 913. The number of RINs assigned

to each batch corresponds to the amount of ethanolequivalent energy per gallon in that batch. See 40

C.F.R. § 80.1415; Monroe Energy, 750 F.3d at 913.

RINs remain attached to the renewable fuel until that

fuel is purchased by an obligated party or blended into

fossil fuels to be used for transportation fuel. See ACE,

864 F.3d at 699 (citing 40 C.F.R. § 80.1429(b)(1)—(2)).

At that point the RINs become “separated,” meaning

they are, in effect, a form of compliance credit. Id.

Obligated parties demonstrate their compliance with

their renewable fuel obligations by “retiring” RINs in

annual compliance demonstrations to EPA. 40 C.F.R.

§§ 80.1427(a), 80.1451(a)(1).

Because the four categories of renewable fuel are

nested, obligated parties can comply with their obligations for a type of fuel by retiring any combination of

RINs corresponding to that category of fuels or any

subset thereof. See 40 C.F.R. § 80.1427(a)(3)(i). For

instance, retiring a cellulosic biofuel or biomass-based

diesel RIN counts not only toward the volume obligation for that fuel, but also toward both the advanced

biofuel and total renewable fuel obligations. Thus, “if

one million gallons of cellulosic biofuel are blended

into the fuel supply, the statute allows those one

million gallons to be credited toward the advanced

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biofuel and total renewable fuel obligations in addition

to the cellulosic biofuel obligation.” ACE, 864 F.3d at

698.

Obligated parties who have more RINs than they

need may sell or trade their excess, 40 C.F.R. § 80.1428(b),

or they may “bank” those RINs for use to meet up to

20 percent of their obligations for the following compliance year, Monroe Energy, 750 F.3d at 913; see 40

C.F.R. § 80.1427(a)(1), (5); Regulation of Fuels and

Fuel Additives: Changes to Renewable Fuel Standard

Program, 75 Fed. Reg. 14,670, 14,734-35 (Mar. 26,

2010). Obligated parties without enough RINs to meet

their compliance obligations may purchase RINs, use

banked RINs from the prior year, or carry a deficit

forward to the following year to be satisfied together

with the following year’s obligations. See ACE, 864

F.3d at 699-700; see also 42 U.S.C. § 7545(o)(5)(D); 40

C.F.R. § 80.1427(b).

B. Procedural Background

The procedural history of these cases follows two

paths: first, the proceedings relevant to the challenge

that EPA arbitrarily declined to initiate a rulemaking

to modify the 2010 regulation designating refineries

and importers, but not blenders, as obligated parties;

and second, the proceedings challenging the 2017 Rule.

1. 2007, 2010, and 2017 Point of Obligation

Proceedings

In its 2007 regulations implementing the RFS program, EPA designated refiners and importers, but not

blenders, as the “appropriate” parties to meet the

renewable fuel obligation. 72 Fed. Reg. 23,900, 23,92324 (May 1, 2007). At the time, those designations were

not challenged in court. EPA reaffirmed its designations in a 2010 regulation now commonly known as the

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“point of obligation rule.” 75 Fed. Reg. at 14,721-22

(codified at 40 C.F.R. § 80.1406(a)(1)). During the

2010 rulemaking, several refiners—including petitioner

Valero Energy Corporation—argued that failing to

obligate blenders, who combine renewable fuel with

fossil fuels, would make the RFS program unworkable.

EPA concluded that the program was functioning

adequately and that the burdens and disruption from

changing the point of obligation would outweigh any

benefits. See Summary and Analysis of Comments

3.9.2, Alon J.A. 287-90. Although other aspects of the

2010 regulations were challenged in court, see, e.g.,

Nat’l Chicken Council v. EPA, 687 F.3d 393 (D.C. Cir.

2012); Nat’l Petrochemical & Refiners Ass’n v. EPA,

630 F.3d 145 (D.C. Cir. 2010), the point of obligation

rule was not.

On December 14, 2015, EPA promulgated the volume

requirements for 2014, 2015, and 2016. Renewable

Fuel Standard Program, 80 Fed. Reg. 77,420 (Dec. 14,

2015). In so doing, EPA exercised its general waiver

authority to lower the total renewable fuel volumes

based on a finding of inadequate domestic supply due

to market factors “affecting the ability to distribute,

blend, dispense, and consume . . . renewable fuels” at

the levels required by statute. Id. at 77,435/2. Among

those factors was “the slower than expected development of the cellulosic biofuel industry.” Id. at 77,422.

The agency thought an additional “real world constraint[]”

was the “E10 blendwall”—the difficulty for most

American vehicle engines to run on blends containing

more than 10% ethanol. Id. at 77,423. EPA explained

that those factors made the statutory requirements

“impossible to achieve.” Id. at 77,422/2. This Court

later vacated the general waiver on the ground that

EPA had misinterpreted the statutory term “inadequate

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domestic supply” to include demand-side constraints

such as the E10 blendwall. See ACE, 864 F.3d at 704-13.

On February 12, 2016, sixty days after EPA promulgated the volume requirements for 2014-16, the Alon

Petitioners petitioned this Court for review of the 2010

point of obligation rule. These petitions contend that

the rule was arbitrary and capricious insofar as it

failed to impose the obligation on downstream blenders—

the parties petitioners think are best able to comply

with it. The petitions assert jurisdiction under the

after-arising provision in 42 U.S.C. § 7607(b)(1), which

permits otherwise-untimely challenges to a rule if the

challenges are “based solely on grounds arising after”

the sixty-day deadline for seeking judicial review. The

petitioners assert that EPA’s exercise of its general

waiver authority in the 2014–16 volume regulations,

and its acknowledgment of the RFS program’s

shortcomings as of that time, provided such an afterarising ground.

The Alon Petitioners simultaneously petitioned EPA

to revise the point of obligation rule. Some of their

requests were styled as petitions for a rulemaking.

Others were styled as petitions for mandatory reconsideration under 42 U.S.C. § 7607(d)(7)(B), which

requires EPA to reconsider a rule if centrally important

objections were impracticable to raise during the comment period or “arose after” that period “but within the

time specified for judicial review.” The petitions cited

the waiver in the 2014-16 volume regulations and

EPA’s acknowledgment of program difficulties as

grounds supporting mandatory reconsideration. This

Court held in abeyance the petitions for review of the

point of obligation rule pending resolution of the

petitions to revise it.

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On November 10, 2016, EPA published a proposed

denial of the petitions to revise the point of obligation

rule. On November 22, 2017, after reviewing more

than 18,000 comments on the proposal, EPA denied

the petitions. It concluded that the statutory requirements for mandatory reconsideration were not met, so

it treated all the filings as petitions for a rulemaking.

Denial of Petitions for Rulemaking to Change the RFS

Point of Obligation, EPA-HQ-OAR-2016-0544-0525, at

7 (Nov. 22, 2017) (EPA Denial), Alon J.A. 61. EPA then

denied the petitions on the ground that “changing the

point of obligation would . . . likely result in a decrease

in the production, distribution, and use of [renewable]

fuels” and would “do nothing to incentivize the research,

development, and commercialization of cellulosic biofuel

technologies critical for the growth of the RFS program

in future years.” EPA Denial at 8-9, Alon J.A. 62-63.

Within sixty days (in December 2017 and January

2018), the Alon Petitioners sought judicial review of

that denial, which it cast as a final agency action

under section 7607(b)(1). The two sets of petitions—

the February 2016 petitions for review of the 2010

point of obligation rule and the 2017-18 petitions for

review of EPA’s refusal to reconsider the rule—were

consolidated and are now before us.

2. 2017 Annual Volumetric Proceedings

EPA issued its 2017 annual volumetric rule on

December 12, 2016. The 2017 Rule establishes: (1) the

applicable volume for biomass-based diesel for 2018,

81 Fed. Reg. at 89,751/2; (2) the waiver-adjusted applicable volumes for cellulosic biofuel, advanced biofuel,

and total renewable fuel for 2017, id. at 89,747 tbl.

I-1; and (3) percentage standards for all four fuel types

for 2017, id. at 89,751, tbl. I.B.6-1.

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EPA exercised its mandatory cellulosic waiver

authority to decrease the 2017 applicable volume for

cellulosic biofuel by more than 94 percent, dropping

5.189 billion gallons from the statutory target of 5.5

billion gallons, to 311 million gallons. Id. at 89,750/2;

42 U.S.C. § 7545(o)(2)(B)(i)(III). EPA then had discretion under that same waiver authority to cut as much

as 5.189 billion gallons off the statutory volumes for

advanced biofuel and total renewable fuel. See 42

U.S.C. § 7545(o)(7)(D)(i); 81 Fed. Reg. at 89,762 & tbl.

IV.A-1. EPA partially exercised that authority, reducing the 9-billion-gallon statutory target for advanced

biofuel by 4.72 billion gallons, resulting in an adjusted

applicable volume of 4.28 billion gallons—a greater

than 50% decrease. 81 Fed. Reg. at 89,750–51;

42 U.S.C. § 7545(o)(2)(B)(i)(II). EPA reduced the total

renewable fuel volume requirements by the same

amount, lowering the statutory target of 24 billion

gallons to 19.28 billion gallons.81 Fed. Reg. at 89,751/1;

42 U.S.C. § 7545(o)(2)(B)(i)(I). EPA considered but

decided against also using its general waiver authority

to further lower the applicable volume of total renewable fuel. 81 Fed. Reg. at 89,751/1.

Using the waiver-adjusted applicable volumes, EPA

set the 2017 percentage standards for each of the four

renewable fuel categories. See id. at 89,751, 89,799801. Finally, EPA set the biomass-based diesel applicable volume for 2018 at 2.1 billion gallons. Id. at

89,751/2. EPA received comments urging it to reassess

the point of obligation in the 2017 Rule, but declined

to address them on the grounds that the comments

were “beyond the scope” of the 2017 rulemaking.

Response to Comments at 542, Coffeyville J.A. 761.

After EPA published the 2017 Rule, various parties

petitioned for judicial review. The Coffeyville Petitioners

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contend that EPA erred by refusing to reconsider which

types of parties would bear the direct compliance obligation under the 2017 Rule. They also argue that EPA

arbitrarily calculated the 2017 production of cellulosic

biofuel and arbitrarily exercised its discretionary cellulosic waiver authority, resulting in percentage standards

that are too high. NBB argues that EPA set the 2018

applicable volume for biomass-based diesel too low by

considering factors it should not have and omitting or

incorrectly assessing others. Two trade associations

representing refineries have intervened in defense of

EPA’s biomass-based diesel decision, and a coalition of

trade associations representing renewable fuel producers and refineries have intervened to oppose the

Coffeyville Petitioners’ claims. None of the petitioners’

challenges succeeds.

III. Standard of Review

“This court applies the familiar, deferential standard

announced in Chevron, U.S.A., Inc. v. Natural Resources

Defense Council, Inc., to sustain any reasonable

agency interpretation of ambiguity in the Clean Air

Act.” Nat’l Ass’n for Surface Finishing v. EPA, 795

F.3d 1, 7 (D.C. Cir. 2015). “We employ the deferential

State Farm standard of review when reviewing arguments based on allegedly arbitrary or unreasoned

agency action.” ACE, 864 F.3d at 726 (citing Motor

Vehicle Mfrs. Ass’n of U.S., Inc. v. State Farm Mut.

Auto. Ins. Co., 463 U.S. 29, 43 (1983)). Under that

rubric, EPA’s actions are “presumptively valid provided

[they] meet[] a minimum rationality standard.” Nat.

Res. Def. Council, Inc. v. EPA, 194 F.3d 130, 136 (D.C.

Cir. 1999). We uphold EPA’s actions so long as they

are “reasonable and reasonably explained.” Jackson v.

Mabus, 808 F.3d 933, 936 (D.C. Cir. 2015).

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IV. 2010 Point of Obligation Rule

We start with the Alon Petitioners and their challenges to the 2010 point of obligation rule.

A. Jurisdiction

We begin, as we must, with our jurisdiction. In

general terms, the question presented involves our

review of rules promulgated under the Clean Air Act,

or EPA’s failure to amend them, after the initial

window for seeking judicial review has passed. Various

statutory provisions frame this inquiry.

Section 7607(b)(1) of Title 42 provides for judicial

review of regulations promulgated by the Administrator

of EPA under the Clean Air Act. The first sentence of

section 7607(b)(1) vests this Court with exclusive jurisdiction to review “nationally applicable regulations

promulgated, or final action taken, by the Administrator” under the Act. The fourth sentence of section

7607(b)(1) specifies the time for seeking judicial

review. It imposes a sixty-day time limit, but provides

an exception for petitions based on grounds arising

after the limit: “Any petition for review under this

subsection shall be filed within sixty days from the

date notice of such promulgation, approval, or action

appears in the Federal Register, except that if such

petition is based solely on grounds arising after such

sixtieth day, then any petition for review under this

subsection shall be filed within sixty days after such

grounds arise.”

Section 7607(d) of Title 42 sets forth provisions for

various rulemakings under the Clean Air Act, including

for the “promulgation or revision of any regulation”

involving the RFS program. Id. § 7607 (d)(1)(E).

Section 7607 (d)(7)(B) addresses various issues regarding exhaustion, agency reconsideration, and judicial

18a

review. The first sentence of that provision imposes a

conventional exhaustion requirement, limiting judicial

review to objections “raised with reasonable specificity

during the period for public comment.” The second

sentence requires EPA to reconsider regulations in

certain narrow circumstances: “If the person raising

an objection can demonstrate to the Administrator

that it was impracticable to raise such objection within

such time or if the grounds for such objection arose

after the period for public comment (but within the

time specified for judicial review) and if such objection

is of central relevance to the outcome of the rule, the

Administrator shall convene a proceeding for reconsideration of the rule and provide the same procedural

rights as would have been afforded had the information

been available at the time the rule was promulgated.”

The third sentence of section 7607(d)(7)(B) makes any

“refusal” to provide such mandatory reconsideration

judicially reviewable.

At various times in this litigation, the petitioners

have asserted three different jurisdictional theories.

First, EPA’s refusal to revise the point of obligation

rule in 2017 was a final action reviewable under the

first sentence of section 7607(b)(1), regardless of the

after-arising provision. Second, EPA’s statements and

actions in its 2014-16 volume regulation constitute

after-arising grounds permitting a challenge to the

point of obligation rule as promulgated in 2010. Third,

these same EPA statements and actions triggered a

right to mandatory reconsideration under section

7607(d)(7)(B), which in turn makes the denial of

reconsideration judicially reviewable. As explained

below, we conclude that the first contention is correct,

the second has been abandoned, and the third lacks

merit.

1. Final Agency

7607(b)(1)

19a

Action

Under

Section

In 2016, various refiners petitioned EPA for a

rulemaking to modify the point of obligation rule.

The petitions urged that the need for a modification

became evident in 2015, when EPA waived certain

statutory volume requirements and concluded that

changing economic conditions had made the requirements “impossible to achieve.” 2014-16 Rule, 80 Fed.

Reg. at 77,422/2. In November 2017, EPA denied the

rulemaking petitions on the ground that any current

problems with the RFS program were manageable and

that changing the point of obligation at this juncture

would be disruptive. EPA Denial at 8-9, Alon J.A.

62-63. The refiners sought review of the denial in

December 2017 and January 2018. As petitioners in

this Court, they contend that the November 2017

denial constituted final agency action reviewable

under section 7607(b)(1). We agree.

As noted above, the first sentence of section

7607(b)(1) gives this Court exclusive jurisdiction to

review any nationally applicable “final action” taken

by EPA under the Clean Air Act. The parties agree

that the denial of the rulemaking petitions was

nationally applicable, final, and taken under the Clean

Air Act. It was also agency “action” within the meaning of the statute. That word “bears the same meaning

in [section 7607(b)(1)] that it does under the Administrative Procedure Act,” Whitman v. Am. Trucking

Ass’ns, 531 U.S. 457, 478 (2001), which defines “agency”

to include EPA, 5 U.S.C. § 551(1), and “agency action”

to include “the whole or a part of an agency rule, order,

license, sanction, relief, or the equivalent or denial

thereof, or failure to act,” id. § 551(13) (emphases

20a

added). So, EPA’s denial of the petitions for rulemaking was a reviewable “action.”

The petitions for review were timely. As a general

matter, section 7607(b)(1) requires a petition for

review to be filed within sixty days of when “notice of

such promulgation, approval, or action appears in the

Federal Register.” Here, the “action” at issue—denial

of the petitions for rulemaking—was published in the

Federal Register on November 22, 2017, and the

petitions for review of that action were filed within

sixty days of that date. Moreover, this conclusion does

not depend on the after-arising provision. To the

contrary, because the petitions for review were filed

within sixty days of the “action” under review, the

exception for “grounds arising after such sixtieth day”

was not triggered.

Our caselaw confirms this framing of the jurisdictional issue. In Massachusetts v. EPA, 415 F.3d 50

(D.C. Cir. 2005), this Court held that EPA’s denial of

a petition to regulate greenhouse gas emissions as

air pollutants was itself “final action” reviewable

under section 7607(b)(1). See id. at 53-54 (opinion of

Randolph, J.); id. at 61 (Sentelle, J., concurring in the

judgment). The Supreme Court reversed our judgment

on the merits, but agreed that we had jurisdiction.

Massachusetts v. EPA, 549 U.S. 497 (2007). In

particular, the Court noted that section 7607(b)(1)

“expressly permits review” of EPA’s “rejection of [a]

rulemaking petition.” Id. at 520, 528; see also id. at

517 (section 7607(b)(1) affords “the right to challenge

[this] agency action unlawfully withheld”). Likewise,

in Natural Resources Defense Council v. EPA, 824 F.2d

1146 (D.C. Cir. 1987) (en banc) (NRDC), we held that

a 1985 decision to withdraw proposed amendments to

certain 1976 regulations—which we described as a

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“decision not to amend” the regulations—was “reviewable agency action” under section 7607(b)(1). Id. at

1150 (quotation marks omitted). We concluded that

the petition for review at issue, which on its face

challenged the 1985 withdrawal decision, was not, in

substance, an untimely “‘back-door’ challenge to the

1976 regulations.” Id. On that point, we reasoned that

the petitioners claimed legal errors in the 1985 withdrawal and sought vacatur only of that order. Likewise,

in this case, the petitions for review filed in 2017 and

2018 raise no back-door challenge to the 2010 regulation: the petitions contend that EPA in 2017 arbitrarily

refused to take account of changing economic conditions, and they seek vacatur only of the 2017 order

denying a new rulemaking going forward.

Background principles of administrative law reinforce our conclusion that the denial of a petition to

modify a rule based on changed circumstances is itself

a reviewable order. Ordinarily, the denial of a petition

to amend or rescind a regulation is judicially reviewable. See, e.g., NLRB Union v. FLRA, 834 F.2d 191,

195-96 (D.C. Cir. 1987). When the petition to amend

attacks defects in the regulation as originally promulgated, and when the time limit for seeking review of

the regulation has passed, questions can arise about

whether the time limit is being improperly circumvented. In these circumstances, we have held that the

petitioner cannot raise procedural challenges to the

regulation, but can raise substantive arguments that

the regulation is unauthorized by or conflicts with a

statute. See id. at 196-97. But the circumvention

concern does not even arise when the petitioner raises

arguments about changed circumstances or new

information. Those kinds of arguments—that recent

developments compel the amendment of an older

regulation—are always cognizable through review of

22a

the denial of a petition to amend, though they trigger

an “extremely limited” review on the merits. Id. at 196.

Our decision today harmonizes the judicial-review

provisions of the Clean Air Act with this general

background principle.

EPA recognizes the general rule that, under the

NLRB Union line of cases, the denial of a petition to

amend a rule is a reviewable order, which supports

both challenges based on recent developments and

substantive challenges to the original regulation.

Nonetheless, EPA urges a different rule where the

applicable judicial-review provision contains a time

limit for seeking review and an exception for grounds

arising after the time limit, as in the Clean Air Act. In

those circumstances, according to EPA, a challenge to

the denial of a petition to amend is untimely—and the

denial is thus entirely unreviewable—unless the afterarising provision is satisfied. EPA rests this conclusion

on National Mining Ass’n v. Department of Interior, 70

F.3d 1345 (D.C. Cir. 1995), and American Road &

Transportation Builders Ass’n v. EPA, 588 F.3d 1109

(D.C. Cir. 2009) (ARTBA), but neither decision supports its position.

National Mining involved judicial review under the

Surface Mining Control and Reclamation Act (SMCRA),

which requires petitions for review to be filed “within

sixty days” of the agency action at issue “or after such

date if the petition is based solely on grounds arising

after the sixtieth day.” See 70 F.3d at 1350. In 1986,

parties petitioned the Department of Interior to

rescind a 1979 SMCRA regulation on two grounds.

First, the petitioners argued that the rule was inconsistent with the statute—an argument attacking the

regulation itself and “available” when the regulation

was originally promulgated. See id. After the agency

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declined to rescind the rule, the challengers sought

judicial review. We held that the after-arising provision made this first challenge untimely, by explicitly

requiring challenges to a regulation either to be filed

“within the statutory period” or to “meet the afterarising test.” Id. at 1350-51. At the same time, however,

we held that the petitioners’ second challenge—to the

agency’s 1986 decision refusing to “repeal” the regulation based on changed circumstances—was timely and

reviewable. Id. at 1352. To be sure, we described the

latter challenge as resting on “grounds that arose after

the sixtieth day.” Id. But we failed to explain what

jurisdictional theory that observation supported: a

challenge to the 1979 regulation rendered timely by

the after-arising exception; or a challenge, in substance as well as form, to the 1986 refusal to repeal,

akin to the challenge that we held reviewable in

NRDC. Instead, we simply concluded that, under the

“limited scope of our review,” the agency did not “act[]

unreasonably in denying the petition for rulemaking.”

Id. at 1352-53. Thus, while National Mining blessed

jurisdiction to review agency refusals to amend

regulations based on changed factual circumstances, it

did not ultimately address what we clarify today—the

precise statutory basis for that jurisdiction.

ARTBA applied the reasoning of National Mining to

the Clean Air Act, which also contains a time limit

for judicial review and an exception for after-arising

grounds. ARTBA involved a 2002 petition to amend

1997 regulations on the ground that they allowed

states “to adopt precisely the kinds of regulations that

the statute forbids.” 588 F.3d at 1110. As in National

Mining, the challenge was thus a substantive attack

on a regulation as originally promulgated. We held

that, under National Mining, EPA’s “denial of a

revision-seeking petition does not allow review of

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alleged substantive defects in the original rule even

under the deferential standards applicable to review

of such denials, outside the statutory limitations

period running from the rule[’s] original promulgation.” Id. at 1113 (emphasis added). In other words,

National Mining “require[d] us to treat ARTBA’s petition to EPA as a challenge to the regulations it sought

revised.” Id. at 1110. As a result, dismissal was

necessary unless the petition satisfied the exception

for after-arising grounds, which it did not. See id.

Neither decision controls here, where the 2017 and

2018 petitions for review challenge not the point of

obligation regulation as originally promulgated in

2010, but the failure to amend the regulation in light

of changed circumstances flagged by EPA in 2015.

EPA rejected that argument in 2017, and the petitioners sought review of the rejection within sixty days. In

substance as well as form, the challenge was to the

2017 refusal to amend, not to the underlying 2010

regulation. Under these circumstances, there was no

risk of circumventing the original time limit. Therefore,

there was also no reason to treat the 2010 promulgation

and the 2017 refusal to amend as one-and-the-same

agency action, despite binding APA definitions treating

them as separate.

Precedent aside, EPA’s proposed approach—making

the after-arising provision the exclusive vehicle for

challenging refusals to amend regulations based on

new information or changed circumstances—creates

various difficulties. For one thing, there is a conceptual mismatch between that provision and these kinds

of challenges. Though the after-arising exception and

the opportunity to seek rule revision based on postrulemaking events may seem similar, the first allows

an intervening event to secure judicial review on the

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basis of defects extant at the time of the rulemaking,

whereas the second allows review on the question

whether intervening events have fatally undermined

the original justification for the rule. The arrow of time

runs forward, not backward, so it is at best awkward—

and at worst incoherent—to speak of a later development rendering unlawful an earlier promulgation.

Economic developments in 2015 may have made it

arbitrary for EPA to adhere to the point of obligation

rule in 2017, but they cannot have retroactively made

arbitrary its promulgation in 2010.

Even worse, the Clean Air Act’s after-arising provision, if used to judge the timeliness of challenges based

on new information, would be difficult to apply, capriciously narrow, or both. To satisfy that provision, a

petition for review must be both (i) based “solely” on

after-arising grounds and (ii) filed “within sixty days

after such grounds arise.” 42 U.S.C. § 7607(b)(1). Yet

the case for changing an environmental regulation will

almost never manifest itself at one discrete moment.

Instead, it will accumulate progressively over time, as

scientific knowledge advances or economic conditions

change. And so, under EPA’s approach, the relevant

filing deadlines would become practically unknowable.

When did some environmental risk become serious

and obvious enough to compel a rulemaking to

strengthen an existing regulation? That will usually

be a hard question, and it would be little short of

miraculous if the answer turned out to be on a date

certain within sixty days of the filing of a petition for

review, as required to satisfy the after-arising provision.

In contrast, the approach we have sketched out

produces simple questions and discernible deadlines:

ask when EPA denied the rulemaking petition, then

add sixty days. If possible, we should avoid trying to

26a

fix arbitrarily precise accrual dates for events that

develop incrementally over time. See Nat’l R.R.

Passenger Corp. v. Morgan, 536 U.S. 101, 115-21

(2002). And we should avoid jurisdictional tests that

are complex as opposed to straightforward. See, e.g.,

Hertz Corp. v. Friend, 559 U.S. 77, 94 (2010). Treating

the denial of a petition to amend a rule based on

changed circumstances as reviewable agency action

honors both principles, while attempting to shoehorn

such denials into the after-arising provision does the

opposite.

We acknowledge that, in Oljato Chapter of Navajo

Tribe v. Train, 515 F.2d 654 (D.C. Cir. 1975), we

assumed that the after-arising provision would govern

review of orders denying petitions to modify EPA rules

based on changed circumstances. But our only holdings

were that such petitions must first be presented to

EPA, id. at 666, and then are reviewable directly in

the courts of appeals, id. at 657-65. Moreover, our

assumption was understandable in context; the petitioners had missed the statutory deadline to file a

petition for review (then thirty days), see id. at 657, so

they pressed alternative jurisdictional theories (involving either district-court review or the after-arising

provision) that would avoid that deadline. Furthermore,

we expressly reserved the precise bounds of what

constituted a petition based solely on after-arising

grounds. See id. at 666-68. Finally, we stressed that

review should generally be available “when new

information casts doubt upon the validity of a

[regulatory] standard.” Id. at 665. At the time, the

after-arising provision contained no separate deadline

requiring a petition for review to be filed within sixty

days of the after-arising ground. See id. at 657 n.3. So

the difference between “direct review” of a regulation

through the after-arising provision and review of a

27a

“refusal to revise” the regulation appeared largely

semantic. See id. at 666. But, two years after Oljato

was decided, Congress amended section 7607(b)(1) to

include the separate filing deadline, see Pub. L. No. 9595 § 305(c)(3), 91 Stat. 685, 776 (1977), which, as

explained above, made the after-arising provision a

singularly poor vehicle for securing the review that

Oljato assumed would be readily available.

After Oljato, we held in Group Against Smog &

Pollution v. EPA, 665 F.2d 1284 (D.C. Cir. 1981), that

the failure to challenge a 1974 regulation within the

original sixty-day deadline did not bar “judicial review

of the agency’s subsequent refusal to revise the

standard on the basis of new information.” Id. at 1291.

Quoting liberally from Oljato, we suggested that such

review would proceed through the after-arising provision. Id. at 1289. But we permitted review even though

the after-arising provision, as amended, could not

have applied. The case involved comments filed with

EPA in April 1977, which we treated as a petition for

a rulemaking. Id. at 1290 & n.47. On April 13, 1978,

EPA declined to amend the rule as requested. Id. at

1288. The ensuing petition for review was filed on

June 12, 1978—more than a year after the technological changes discussed in the comments, but precisely

sixty days after the refusal to amend. See id. Because

the petition for review was not filed within sixty days

of the asserted after-arising grounds, the after-arising

provision plainly did not apply. So, review must have

rested on the theory that the refusal to amend was

itself a reviewable action triggering its own sixty-day

filing window.

The approach we follow here—treating denials of

rulemakings based on new facts as independently

reviewable decisions—does not reduce the after-arising

28a

provision to surplusage. Our cases have recognized

other circumstances triggering the after-arising provision, including judicial decisions that significantly

“changed the legal landscape” faced by petitioners,

Honeywell Int’l, Inc. v. EPA, 705 F.3d 470, 473 (D.C.

Cir. 2013), and “the occurrence of an event that ripens

a claim,” Coalition for Responsible Regulation v. EPA,

684 F.3d 102, 129 (D.C. Cir. 2012) (per curiam). In

cases like these—where, for example, an intervening

statute, regulation, or judicial decision extends old

regulations to new parties—the after-arising ground is

easily dated, the relevant filing deadlines are clear,

and so the provision functions predictably. Moreover,

where the after-arising provision does apply, it permits the petitioner to contend not only that changed

circumstances warrant amending an existing regulation but also that the regulation was unlawful as

originally promulgated. See, e.g., Honeywell, 705 F.3d

at 473.

For these reasons, we conclude that we have

jurisdiction to consider the petitioners’ argument that

EPA arbitrarily refused to amend the point of

obligation rule based on the changed circumstances

cited by the petitioners.

2. After-Arising

7607(b)(1)

Grounds

Under

Section

The February 2016 petitions for review, filed before

EPA resolved any of the rulemaking petitions, rested

on the alternative jurisdictional theory that EPA’s

publication of the 2014-16 volume requirements constituted an after-arising ground within the meaning of

section 7607(b)(1). Our conclusion above does not moot

this question, because if this alternative theory were

valid, then the petitioners could directly attack the

point of obligation rule as originally promulgated.

29a

Nonetheless, the petitioners have abandoned this

theory of jurisdiction. In their merits briefs, they never

actually attack the 2010 rule as originally promulgated; instead, they challenge only the 2017 denial of

their rulemaking petitions. Moreover, in requesting

relief, they do not ask us to set aside the 2010 rule, but

only to “vacate the [2017] Denial[] and remand to

EPA” for a rulemaking to change the point of obligation rule going forward. Alon Br. 58. And at oral

argument, they disclaimed any challenge to the 2010

rule itself and confirmed that their only challenge was

to EPA’s 2017 refusal to revise the point of obligation

rule. See Rec. of Oral Argument at 2:18:50-2:19:15.

3. Mandatory Reconsideration Under Section

7607(d)(7)(B)

Finally, the petitioners assert jurisdiction under

section 7607(d)(7)(B), on the ground that EPA erroneously denied petitions for mandatory reconsideration

of the point of obligation rule. To review, section

7607(d)(7)(B) provides in relevant part that only

objections “raised . . . during the period for public

comment” may be “raised during judicial review.” But

if the objector “can demonstrate to the Administrator

that it was impracticable to raise such objection within

such time or if the grounds for such objection arose

after the period for public comment (but within the

time specified for judicial review) and if such objection

is of central relevance to the outcome of the rule,” then

EPA must “convene a proceeding for reconsideration

of the rule,” and any refusal to do so is judicially

reviewable. Here, the petitioners assert that the

ground for their objections—EPA’s statements and

actions in its 2014-16 volume regulation—arose “after

the period for public comment” on the 2010 point of

30a

obligation rule, and that the objections are “of central

relevance to the outcome of the rule.”

The petitioners misapprehend the statutory text

and structure. Section 7607(d)(7)(B) does not extend

the jurisdictional deadline to seek judicial review

imposed in section 7607(b)(1); instead, it specifies a

non-jurisdictional exhaustion requirement. See EPA v.

EME Homer City Generation, L.P., 572 U.S. 489, 512

(2014). Its first sentence generally requires parties

to raise objections “during the period for public

comment” in order to later present them in court. Its

second sentence allows a narrow exception when a

centrally important objection cannot feasibly be raised

during the comment period—either because “the grounds

for such objection arose after the period for public

comment,” or because commenting was otherwise

“impracticable.” If an objection fits within this exception, the consequences are weighty: EPA must grant

reconsideration and conduct a new, full-dress, noticeand-comment rulemaking. And if EPA denies

reconsideration, the objector may seek judicial review.

This “limited exception” to the normal exhaustion

deadline, Util. Air Regulatory Grp. v. EPA, 744 F.3d

741, 746 (D.C. Cir. 2014), does not come with a free

pass from the subsequent deadline to seek judicial

review. To the contrary, the second sentence of section

7607(d)(7)(B) covers only objections that arise after

the close of the comment period, yet within the time

specified for judicial review. As noted above, that time

for judicial review—sixty days from the promulgation

of the final rule—is specified in section 7607(b)(1).

Section 7607(d)(7)(B) does not enlarge that filing period,

but merely fills a narrow gap within it: allowing

orderly exhaustion of important objections that “first

became known to the petitioner after the comment

31a

period ended, but before the period for petitioning for

review expired.” Am. Petroleum Inst. v. Costle, 665

F.2d 1176, 1192 (D.C. Cir. 1981). We recognize that, as

a textual matter, the statutory phrase “but within the

time specified for review” qualifies the requirement

that the grounds must have arisen “after the period for

public comment,” but not the alternative requirement

that “it was impracticable” to raise the objection

“during the period for public comment.” However, the

petitioners do not invoke the impracticability prong of

section 7607(d)(7)(B). Moreover, we have construed

that prong to cover instances when the final rule was

not a logical outgrowth of the proposed rule, Clean Air

Council v. Pruitt, 862 F.3d 1, 10 (D.C. Cir. 2017) (per

curiam), which likewise involve problems during the

period for public comment on or petitioning for review

of the regulation itself—not problems that arise when

circumstances change years or decades later.

The petitioners argued in briefing that the “time

specified for judicial review” referenced in section

7607(d)(7)(B) encompasses not only the initial sixtyday window after a rule’s promulgation, but also the

secondary sixty-day limit from after-arising grounds

in the fourth sentence of section 7607(b)(1). But as

noted above, the petitioners abandoned at oral argument any reliance on the latter after-arising provision.

Moreover, their theory would transform what we have

described as a “limited” gap-filling provision, Util. Air

Regulatory Grp., 744 F.3d at 746, into a perpetually

looming threat of mandatory notice-and-comment

reconsideration. Tellingly, the petitioners can cite no

case employing section 7607(d)(7)(B)’s mandatory

reconsideration procedure for objections that arose

after the close of the initial window for judicial review.

Their interpretation would “make a mockery of

Congress’ [s] careful effort to force potential litigants

32a

to bring challenges to a rule issued under this statute

at the outset.” Am. Rd. & Transp. Builders Ass’n v.

EPA, 705 F.3d 453, 458 (D.C. Cir. 2013) (quotation

marks omitted).

Because the petitioners’ objections to the point of

obligation rule did not arise within the initial window

for judicial review of the 2010 point of obligation rule,

but only some five years later, EPA properly denied

mandatory reconsideration.

B. Merits of Challenges to EPA’s Refusal to

Revise the 2010 Point of Obligation Rule

The Alon Petitioners offer an array of arguments to

challenge the denial. None, however, is persuasive.

We are reviewing EPA’s denial of a petition for

rulemaking to amend the agency’s point of obligation

rule. See supra Part IV.A.1. Accordingly, our review is

“‘extremely limited’ and ‘highly deferential.’” New York

v. EPA, 921 F.3d 257, 261 (D.C. Cir. 2019) (quoting

Massachusetts, 549 U.S. at 527-28). “To set aside the

agency’s judgment, [we] must conclude that EPA had

not ‘adequately explained the facts and policy concerns

relied on’ or that those facts did not ‘have some basis

in the record.’ Id. (quoting WildEarth Guardians v.

EPA, 751 F.3d 649, 653 (D.C. Cir. 2014)). We have no

basis for such a conclusion. In denying the petition for

rulemaking, EPA considered the “information currently before” it and determined “that the point of

obligation is appropriately placed,” wrestling with the

petitioners’ claims to the contrary. EPA Denial at 8,

Alon J.A. 62. As is evident from our discussion below,

EPA did so with enough thoroughness and reasonableness to satisfy our limited, deferential review.

33a

We start with EPA’s reasoning, which petitioners

say is arbitrary and capricious. See 42 U.S.C.

§ 7607(d)(9)(A).

At the root of petitioners’ claim is a single premise:

that the current point of obligation misaligns incentives by requiring those who refine fossil fuel, but not

those who blend it, to meet the RFS program’s annual

standards. In petitioners’ view, this misalignment

forces refiners to purchase RINs to satisfy their RFS

obligations, jacking up their costs, while giving windfall profits to blenders, who produce (but don’t consume)

RINs. From this cycle of “RINsanity,” petitioners say,

flow harms galore. Alon Reply Br. 25. Higher RIN

prices not only threaten the financial viability of

refiners (putting our economy and energy security in

jeopardy), see, e.g., Alon Br. 46, but they incentivize

RIN hoarding, which feeds market volatility, and gives

some market participants an unfair leg up, see, e.g., id.

at 40.

The problem with this argument, however, is that

EPA reasonably explained why, in its view, there is no

misalignment in the RFS program. According to EPA,

refiners “recover the cost of the RINs they purchase”

by passing that cost along in the form of “higher prices

for the petroleum based fuels they produce.” EPA

Denial at 25, Alon J.A. 79. It grounded that conclusion

in studies and data in the record. EPA and the authors

of the pertinent studies took advantage of the fact that

there are pairs of petroleum products in which one

variant is subject to the RIN obligation (such variants

being awkwardly called “obligated fuels”), whereas its

not-quite-identical twin is not. For example, gasoline

and diesel sold for use in the United States are

“obligated,” whereas the same fuels sold for export are

not. EPA Denial at 23, Alon J.A. 77. The same goes for

34a

domestic diesel fuel, which is “obligated,” and jet fuel,

which is not. Christopher R. Knittel et al., The PassThrough of RIN Prices to Wholesale and Retail Fuels

Under the Renewable Fuel Standard 4 (July 2015)

(Knittel), Alon J.A. 534. Comparing these pairs, the

agency found that as RIN prices increased, a gap

“open[ed] up between” the price for obligated and

unobligated fuels, a gap rather precisely matching

the contemporaneous increase in RIN price—a strong

indication that refiners were “recoup[ing] the costs

associated with RIN prices.” EPA Denial at 23, Alon

J.A. 77.

Further confirming the price relationship, Professor

Knittel and his colleagues found that 73% of a change

in RIN price was passed through in the form of higher

petroleum prices in the same day, 98% within two

business days. Knittel 26, Alon J.A. 536.

Reviewing the findings, EPA (accurately) reported

that the papers by Knittel and his colleagues, and by

Argus Consulting Services, “concluded that the RIN

cost was generally included in the sale prices of

obligated fuels.” EPA Denial at 25, Alon J.A. 79; see

Knittel 26, Alon J.A. 536; Argus Consulting Services,

Do Obligated Parties Include RINs Costs in Product

Prices? 15 (Feb. 2017), Alon J.A. 564 (“There are very

specific correlating price data for diesel that indicate

that refiners . . . pass along the RINs cost . . . .”).

A similar analysis, EPA concluded, reveals that just

as (obligated) refiners do not pay excess costs, neither

do blenders (who are not obligated under the program)

nor integrated refiners (who perform their own inhouse blending) reap windfall profits. True, both earn

RINs, without purchasing them on the open market,

by blending renewable fuel into petroleum blendstock.

And true, as well, both can sell those RINs, enjoying

35a

whatever revenues market conditions and their own

efficiencies permit. But as EPA quite accurately

explained, this is only half the equation. In a competitive market there’s no such thing as a free lunch, and

blenders and integrated refiners pay their tab just as

others do; they just do so indirectly. To offer finished

fuel without attached RINs at a competitive price,

these entities must discount their blended fuel by

roughly the value of the RINs that they detached and

kept for themselves. EPA Denial at 29, Alon J.A. 83.

In other words, they “sell the finished transportation

fuel at a loss,” but “maintain[] profitability through

RIN sales.” Id. at 27-28, 29, Alon J.A. 81-82, 83.

To be sure, in response to EPA’s proposed denial,

commenters criticized the studies relied on by the

agency. They contended, for example, that Professor

Knittel and his colleagues erred by removing certain

spreads from the analysis, by including others, and by

pooling the results of various comparisons. See EPA

Denial at 25, Alon J.A. 79. But petitioners have not

raised these arguments here, and for that reason we

do not consider them. While petitioners do complain

that EPA relied on a “preliminary” analysis, see Alon

Br. 54; Alon Reply Br. 23, that objection—whatever its

persuasive force—says nothing about the other studies

in the record (for example, by Professor Knittel et al.).

Petitioners try, instead, to trace various refiner

problems to EPA’s refusal to obligate blenders. They

suggest that the alleged misplacement of the point of

obligation causes bankruptcies, see, e.g., Alon Br. 3, 47,

and inflicts economic hardship on small refineries, see,

e.g., id. at 49, especially in the form of inflicting wildly

disproportionate RIN acquisition costs on them, see,

e.g., Alon Reply Br. 26. But some of these events

occurred after EPA issued its denial, see, e.g., Alon Br.

36a

49 (“following the Denial”); Alon Reply Br. 26 (“just

after the Denial”), and are therefore not properly

before us, see Environmental Defense Fund, Inc. v.

Costle, 657 F.2d 275, 284 (D.C. Cir. 1981). More

importantly, the claims presuppose that refiners

cannot recover their RIN costs and that blenders reap

windfall profits—suppositions that, as discussed

above, EPA reasonably rejected.

Petitioners respond by plucking snippets from the

denial, stringing them together with contrasting

(bolded) conjunctions, and asserting that EPA’s

“discussion of RIN prices” is “irreconcilably inconsistent.” Alon Br. 53. But we find no inconsistency on

EPA’s part.

Take one of petitioners’ examples:

. . . RIN prices had no “significant impact on retail

gasoline (El 0) prices,” JA75;

although “RINs . . . provide a price signal to

consumers to help achieve . . . greater renewable

fuel production and use,” JA75.

Alon Br. 53 (second and third alterations in original)

(quoting EPA Denial at 21, Alon J.A. 75). At first

blush, the two comments, located on the very same

page, seem inconsistent. How could RIN prices have

no “significant impact” on retail prices, while, at the

same time, provide “a price signal to consumers”?

They can do so for the simple reason that the

remarks refer to different things, a detail omitted from

petitioners’ brief. This becomes apparent when the

passage from which petitioners plucked their quotes

(bolded and underscored below) is viewed in full:

External, non-EPA assessments similarly

concluded that increased RIN prices had

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not had a significant impact on retail

gasoline (E10) prices. When RIN prices rise,

the market price of the petroleum blendstocks

produced by refineries also rise to cover the

increased RIN costs, in much the same way

as they would rise in response to higher crude

oil prices. The effective price of renewable

fuels (the price of the renewable fuel with

attached RIN minus the RIN price), however,

decreases as RIN prices increase. When

renewable fuels are blended into petroleum

fuels these two price impacts generally offset

one another for fuel blends such as E 10 with

a renewable content approximately equal to

the required renewable fuel percentage

standard. Higher RIN prices also generally

result in higher prices for fuels with lower

renewable content (such as E0 or petroleum

diesel) and lower prices for fuels with higher

renewable content (such as E85 or B20). The

cost of the RIN therefore serves as a crosssubsidy, reducing the price of renewable fuels

and increasing the price of petroleum based

fuels in transportation fuel blends, thus

incentivizing increased blending of renewable

fuels into the transportation fuel pool. In this

way the RINs also help provide a price

signal to consumers to help achieve the

Congressional goals of greater renewable

fuel production and use. Fuels with higher

renewable content are relatively cheaper to

consumers than they would be absent high

RIN prices, while fuels with lower renewable

content are relatively more expensive when

RIN prices are high.

EPA Denial at 20-21, Alon J.A. 74-75.

38a

As we can see, the first statement (no significant

price impact) is referring to the price of E10—a blend

of 90% gasoline, 10% ethanol. As EPA explained, RINs

work as a “cross-subsidy,” effectively taxing the use of

petroleum-based fuels (e.g., gasoline) and subsidizing

the use of renewables (e.g., ethanol) in making a

blended transportation fuel like E10. EPA Denial at

21, Alon J.A. 75.

Before we dig in further, let’s take a step back. We

must first recognize that EPA assumes that we are

talking of a market where the RFS program, in effect,

mandates minimum levels of renewables in marketed

fuels, a mandate that necessarily impacts fuel prices.

EPA is not making a claim that the mandatory

inclusion of renewables in transportation fuel renders

a gallon of gasoline lawfully purchased at the pump

cheaper than it would have been absent the RFS

program.

To see what this means, start on the subsidy side:

Suppose a blender can realize $2.25 on a gallon of

ethanol with an attached RIN. If the blender can

detach and sell that RIN for $0.05, then the net

ethanol value is only $2.20—a $0.05 savings that in a

competitive market should pass through to consumers.

Now take the tax side: Because refiners must purchase

RINs to satisfy the RFS obligations that arise from

selling gasoline to blenders, a blender’s value for a

gallon of gasoline may rise, due to the RFS program,

from, say, $2.75 to $2.76. See Dallas Burkholder,

Office of Transportation & Air Quality, EPA, A

Preliminary Assessment of RIN Market Dynamics,

RIN Prices, and Their Effects 17, EPA-HQ-OAR-20160544-0009 (May 14, 2015), Alon J.A. 337. As a result

of both price impacts, EPA described, blended fuels

with a higher percentage of renewable content (e.g.,

39a

85% ethanol) will be cheaper than they would have

been (absent the program), whereas fuels with a lower

percentage of renewable content (e.g., pure gasoline)

will be more costly than they would have been (absent

the program). EPA Denial at 21, Alon J.A. 75. For E10,

the “two price impacts generally offset one another,”

so (back to the first statement) any change in RIN

price generally has no “significant impact on” the E10

price. Id.

But that’s just E10. There is an effect (of differing

magnitude) on, say, E85 or E0. And that is where the

second statement (“provide a price signal”) comes in:

the signal arises from a comparison of relative prices

across the spectrum of transportation fuels. Again, as

EPA explains, “[f]uels with higher renewable content

are relatively cheaper to consumers than they would

be absent high RIN prices, while fuels with lower

renewable content are relatively more expensive when

RIN prices are high.” Id. The two statements are

consistent.

Continuing the search for inconsistency, petitioners

direct our attention to “EPA’s past pronouncements.”

Alon Br. 50. In them, they see an irrational “aboutface”—with EPA saying, at first, that “low RIN prices

[were] a sign that the [RFS program] was working,”

but claiming, now, “that high RIN prices are . . .

desirable.” Id. at 51-52. Again, that’s not quite right.

All EPA originally said was that when it first adopted

the point of obligation, it did so based, in part, on its

“expectation at that time that there would be an excess

of RINs at low cost.” Regulation of Fuels and Fuel

Additives: Changes to Renewable Fuel Standard

Program, 74 Fed. Reg. 24,904, 24,963/2 (May 26, 2009)

(proposed rule); see also Alon Br. 50 (citing EPA Denial

at 13, Alon J.A. 67 (citing, in turn, 74 Fed. Reg. at

40a

24,963)). EPA did not suggest that low RIN prices were

a sign of market health—nor that high prices were a

cause for alarm.

In any case, EPA addressed petitioners’ concern

over high RIN prices head on; the agency explicitly

determined, on the current record, that “higher RIN

prices” are not “indicative of a dysfunctional RIN

market.” EPA Denial at 19, Alon J.A. 73. Rather, EPA

explained, these prices accurately reflect the increasing cost associated with “getting ever-greater volumes

of renewable fuel into the transportation fuel pool—

the explicit goal [of] the RFS program.” Id. Put more

bluntly, the increases in RIN prices are a completely

understandable effect of the program’s ever-increasing

pressure to expand renewable volumes. Pushing out

along the supply curve takes the raw market price of

the RIN-eligible fuel steadily into higher realms—

except to the extent that production innovations or

economies may tend to lower costs. So far as appears,

it has nothing to do with EPA’s allocation of the

obligation.

What about EPA’s concern, petitioners ask, that

including blenders in the point of obligation would

expand the number of obligated parties and, as a

result, ratchet up the program’s complexity? Isn’t that

hard to square with EPA’s claim, made years earlier,

that “essentially all downstream blenders . . . are

[already] regulated parties”? Alon Br. 42 (quoting 75

Fed. Reg. at 14,722/2). Again, not at all. Although the

participation of all (or nearly all) blenders in the

RIN market subjects them to RFS registration,

recordkeeping, and reporting requirements, “the majority of these downstream [regulated] parties are . . .

currently not obligated parties.” EPA Denial at 69,

Alon J.A. 123 (emphasis added). As EPA explained,

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there “is a significant distinction between being a

‘regulated party’ and being an ‘obligated party’” Id.

“Obligated parties must meet all of [the requirements

faced by regulated parties] and also calculate an

annual renewable volume obligation, acquire the

appropriate number of RINs in the market, practic[e]

due diligence to ensure [the RINs’] validity, file annual

compliance reports demonstrating compliance, and

maintain records to that effect.” Id. at 69 n.205, Alon

J.A. 123 (emphasis added); see, e.g., 40 C.F.R.

§§ 80.1427(a), 80.1450(a), 80.1451(a), 80.1454(a). It

was not unreasonable for EPA to conclude that imposing these burdens on additional entities would add to

the program’s complexity (and therefore be undesirable absent an adequate offsetting benefit).

Nor was it unreasonable to find that going down

this route—overhauling a foundational element of the

program would create “uncertainty in the fuels marketplace.” EPA Denial at 2, Alon J.A. 56. As EPA said,

“all parties regulated in the RFS program have made

significant investments and decisions about their participation in the program and their position in the

market on the basis of the existing regulations,

including the definition of obligated parties.” EPA

Denial at 79, Alon J.A. 133. In these circumstances, it

isn’t hard to imagine how changing course could throw

players off their game. Of course, as petitioners note,

uncertainty may have “plagued the RFS Program for

years.” Alon Br. 37. But true or not, EPA needn’t pile

on; the cure for uncertainty isn’t spawning more

uncertainty.

Taking a step back, petitioners launch a closing

broadside against the entire process. They assert that

EPA “disregarded this Court’s remand” in ACE, 864

F.3d at 737, and arbitrarily credited some comments

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over others. Alon Br. 31-32, 55-56. But the ACE

remand required, at most, that the agency “address

the point of obligation issue.” 864 F.3d at 737. And, as

detailed throughout this opinion, the agency has done

so reasonably, analyzing the data and explaining its

decision. Nothing more was required.

* * *

We have considered the Alon Petitioners’ other

arguments and have found them to be either without

merit or, in the case of the argument relying on 42

U.S.C. § 7545(o)(5)(A), see Alon Br. 34, insufficiently

developed, see, e.g., Masias v. EPA, 906 F.3d 1069,

1077 (D.C. Cir. 2018). For the foregoing reasons, the

petitions for review are denied.

V. 2017 Annual Volumetric Rule

We turn now to the Coffeyville Petitioners’

challenges.

A. Point of Obligation

We first consider the Coffeyville Petitioners’ challenge to EPA’s decision in the 2017 Rule not to reassess

which categories of industry players are “obligated

parties” under the renewable fuel program. As the

Coffeyville Petitioners read it, the statutory provision

requiring EPA to set annual renewable fuel percentage standards also imposes on EPA a nondiscretionary

duty to reconsider—every year—which types of entities

are obligated to demonstrate to EPA compliance with

the percentage standards. See 42 U.S.C. § 7545(o)(3)(B).

They claim EPA shirked that duty when it treated the

issue as beyond the scope of its 2017 annual rulemaking. EPA counters that it identified the obligated

parties in 2007 pursuant to Congress’s mandate to set

“compliance provisions” for the new renewable fuel

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program, id. § 7545(o)(2), reaffirmed that decision in

2010, and that nothing in the mandate to calculate the

annual percentage standards requires it to reconsider

the point of obligation each year. EPA also asserts that

it appropriately addressed the Coffeyville Petitioners’

complaints that it obligated the wrong parties in a

separate proceeding from its annual volumetric

rulemaking.

1. Jurisdiction

EPA and a coalition of Respondent-Intervenors

representing the renewable fuel and refinery industries

assert that we lack jurisdiction because the Coffeyville

Petitioners effectively challenge the compliance rule

that has been on the books for a decade or so, see

40 C.F.R. § 80.1406(a)(1), and did not petition within

60 days of its publication or within 60 days of any

valid “grounds arising” thereafter. See 42 U.S.C.

§ 7607(b)(1); Med. Waste Inst. v. EPA, 645 F.3d 420,

427 (D.C. Cir. 2011). But petitioners are not challenging EPA’s decision to adopt the rule in 2007 or retain

it in 2010. Rather, they contend that the provision

calling on EPA to set annual volumes of biofuels

“applicable to refineries, blenders, and importers, as

appropriate,” requires EPA to reassess each year

whether the point of obligation set when the agency

established the program is still “appropriate,” or if

EPA should re-assign it and restructure the RIN

market and other compliance infrastructure going

forward. See 42 U.S.C. § 7545(o)(3)(B)(ii)(I). That

challenge was timely filed within 60 days of the

promulgation of the annual fuel standards. See supra

Part IV.A.1.

44a

2. Merits

This dispute turns on the roles of two provisions of

the statute directing the EPA to establish and run a

Renewable Fuel Program, 42 U.S.C. § 7545(o)—

paragraphs (2) and (3).

Paragraph (2) directs EPA to “promulgate regulations”

setting up a program to “ensure that transportation

fuel sold or introduced into commerce in the United

States . . . contains at least the applicable volume[s] of

renewable fuel,” as specified in subparagraph (2)(B).

Id. § 7545(o)(2)(A)(i). Among the parameters Congress

required EPA to include were “compliance provisions

applicable to refineries, blenders, distributors, and

importers, as appropriate,” to ensure that the requirements of paragraph (2), including the applicable volume

requirements specified in subparagraph (2)(B), are

met. Id. § 7545(o)(2)(A)(iii)(I), (B). There is no question

that EPA has authority to set those parameters,

including the point of obligation, and to adjust them if

a change is needed.

Paragraph (3), in turn, requires EPA to determine

and publish annual renewable fuel obligations designed

to “ensure[] that” the applicable volumes specified in

paragraph (2) are met. Id. § 7545(o)(3)(B)(i). Those

renewable fuel obligations must:

(I) be applicable to refineries, blenders, and

importers, as appropriate;

(II) be expressed in terms of a volume

percentage of transportation fuel sold or

introduced into commerce in the United

States; and

45a

(III) . . . consist of a single applicable

percentage that applies to all categories of

persons specified in subclause (I).

Id. § 7545(o)(3)(B)(ii)(I)–(III).

The parties’ dispute centers on the meaning of “as

appropriate” in subclause (3)(B)(ii)(I). The Coffeyville

Petitioners contend that the phrase unambiguously

requires EPA annually to reconsider which parties it

is “appropriate” to obligate to meet the renewable fuel

obligations. EPA responds that the statute is, at most,

ambiguous as to whether Congress expected EPA

annually to revisit the obligated-parties designation,

or whether the agency may generally rely on the

“appropriate[ness]” finding it made pursuant to its

paragraph (2) authority. We begin by asking “whether

Congress has directly spoken to the precise question

at issue,” and conclude that it has not. Chevron, 467

U.S. at 842.

EPA reads “as appropriate” in paragraph (3) to

mean that the agency has “discretion” to decide

whether, when, and how to reassess which of three

types of industry actors—refineries, blenders, and

importers—should continue to bear the point of

obligation, as originally designated in the compliance

provisions. See EPA Denial, Coffeyville J.A. 779-80. At

oral argument, the agency conceded that its exercise

of this discretion is reviewable, so that the exclusion of

the point of obligation issue from an annual rulemaking could, under other circumstances, constitute an

abuse of discretion. Rec. of Oral Arg. 1:22:22-1:24:00;

1:37:45-1:40:11.

The Coffeyville Petitioners object that the phase

“applicable . . . as appropriate” means applicable as

contemporaneously determined to be appropriate in

46a

the annual volumetric rulemakings. Coffeyville Br. 3033; see also Conc. Op. 4-5, 7. But paragraph (3) does

not specify when or in what context EPA must make

its appropriateness determination, nor does the phrase

“as appropriate” itself specify a particular temporal

dimension—as between, for example, parties appropriately designated in the past (as EPA interprets it)

and parties now appropriately selected (as Coffeyville

insists). The term “appropriate” “naturally and traditionally includes consideration of all the relevant

factors,” Michigan v. EPA, 135 S. Ct. 2699, 2707 (2015)

(quoting White Stallion Energy Center, LLC v. EPA,

748 F.3d 1222, 1266 (D.C. Cir. 2014) (Kavanaugh, J.,

concurring in part and dissenting in part)), but it does

not dictate when that consideration must be made.

In other words, the requirement that the point of

obligation be “appropriate” is at most grounds for

assessing whether the agency adequately explained its

policy choices regarding the appropriateness determination, not for imposing our own gloss on that broad

term as a matter of law. See Kisor v. Wilkie, 139 S. Ct.

2400, 2448-49 (2019) (Kavanaugh, J., concurring in

the judgment) (“[S]ome cases involve regulations that

employ broad and open-ended terms like ‘reasonable,’

‘appropriate,’ ‘feasible,’ or ‘practicable.’ Those kinds

of terms afford agencies broad policy discretion, and

courts allow an agency to reasonably exercise its

discretion to choose among the options allowed by the

text of the rule. But that is more State Farm than

Auer” or Chevron (emphasis added)). Here, as explained

below, EPA reasonably exercised its discretion, and

explained its decision, to address the point of obligation issue in a separate proceeding from its annual

volumetric rulemaking.

The fact that paragraphs (2) and (3) both include the

phrase “as appropriate” does not make the Coffeyville

47a

Petitioners’ the only permissible interpretation. Even

if, as our colleague contends, Conc. Op. 7, the two

phrases bear the exact same meaning, but see Coffeyville

Br. 30-31 (arguing that paragraphs (2) and (3) are

“worded differently” and have “different contexts”),

paragraph (3) simply does not dictate when or in what

context EPA must make the appropriateness determination. It is the surrounding context, not the

phrases themselves, that suggests when EPA might

make that choice.

Unable to point to any express textual requirement

that EPA annually reconsider the point of obligation,

the Coffeyville Petitioners contend that, had Congress

intended to allow EPA in annual volumetric rulemakings to rest on its paragraph (2) appropriateness

determination, subclause (3)(B)(ii)(I) could have more

simply cross-referenced paragraph (2). But replacing

subclause (3)(B)(ii)(I) with a simpler cross-reference

would not have achieved quite the same effect.

While refineries, blenders, importers, and distributors

may all be subject to compliance provisions under

paragraph (2), paragraph (3)’s applicability provision

points to a more limited universe of potential obligated

parties—to refineries, blenders, and importers, but not

distributors. That supports EPA’s understanding of

subclause (3)(B)(ii)(I) as a cross-reference that also

clarifies a limit on EPA’s options in setting the point

of obligation. See 72 Fed. Reg. at 23,923/2 (preamble

for compliance rule referencing paragraph (3)’s applicability provision).

We are unpersuaded by the suggestion that such

limitation was so clear even without subclause

(3)(B)(ii)(I) that EPA’s reading of that applicability

provision renders it superfluous. The suggestion is

that, because distributors do not “introduce” fuel into

48a

commerce, they could not be obligated parties in any

event, with or without the applicability provision. Our

colleague posits that blenders—but not distributors—

can in fact “introduce” transportation fuel into commerce by blending gasoline and diesel fuel with other

fuels that have not already been introduced by

someone else. Conc. Op. 11. But that argument rests

on a complicated series of inferences from spare

statutory text, as well as post-enactment regulations

that do not necessarily show what the statute must

have meant. For example, our colleague reasonably

infers that the national “volume[] of transportation

fuel,” 42 U.S.C. § 7545(o)(3)(A), must be counted at the

first moment each gallon of fuel enters commerce, in

order to avoid double-counting. But, the statute

nowhere states the point directly. Still less clearly

does the statute state our colleague’s corollary—

necessary to the surplusage argument—that the point

of obligation must also be placed, if at all, at the first

moment a gallon of fuel enters commerce. That

corollary is less obvious, because the statutory link

between the point of obligation and entry into

commerce is not ironclad: All parties agree that not

every gallon of transportation fuel must be subject to

the point of obligation upon entry into commerce. The

statute plainly allows EPA to obligate an “appropriate” subset of the three categories of parties. And

obligating blenders would involve double counting

unless the transportation fuel they use to create

blends were not already counted upon its importation

or sale to them. Under the circumstances, it is reasonable to read subclause (3)(B)(ii)(I) as clarifying what is

at best a non-obvious inference that distributors

cannot be subjected to the point of obligation.

So subclause (3)(B)(ii)(I) as EPA reads it is not a

superfluity, but makes clear that EPA may have

49a

permissibly placed the point of obligation on refineries, blenders, and importers, but not distributors. For

the same reason, subclause (3)(B)(ii)(III), which

requires that the annual standards apply “to all

categories of persons specified in subclause (I),” id.

§ 7545(o)(3)(B)(ii)(III), does not contain what our

colleague views as an unnecessary double crossreference to paragraph (2), because it, too, is operative

in not just cross-referencing, but also clarifying a limit

on the three permissible targets of its “single applicable percentage.”

The thrust of the Coffeyville Petitioners’ retort—

that if Congress had wanted to confer discretion or

provide a limiting cross-reference to paragraph (2), it

would have said so more plainly—applies with greater

force against their own reading. Had Congress

intended EPA to consider on an annual basis whether

to redo the point of obligation designation—a designation that no-one disputes is a necessary cornerstone of

the paragraph (2) compliance provisions—it knew how

to impose such a requirement. The Clean Air Act’s

provisions on ambient air quality, for instance, require

EPA to “complete a thorough review” of the air quality

standards “at five-year intervals” and “promulgate

such new standards as may be appropriate.” Id.

§ 7409(d)(1). The Act’s provisions controlling hazardous

air pollutants emitted from major and area sources

require EPA to “review, and revise as necessary” the

applicable emission standards “no less often than

every 8 years.” Id. § 7412(d)(6). Paragraph (3) of the

RFS program, in contrast, does not tell EPA to

“complete a thorough review,” or “review, and revise

as necessary” its point of obligation decision—or

anything even close.

50a

To be sure, EPA’s reading is not ineluctable. We do

not doubt that Congress could have more directly

provided that the renewable fuel obligations do not

apply to distributors. See Conc. Op. 8. But, for the

reasons discussed, we are unconvinced that paragraph

(3) plainly requires EPA to consider adjusting the

point of obligation each year. See Valero Energy Corp.

v. EPA, No. 7:17-cv-00004-O, 2017 WL 8780888, at *4

(N.D. Tex. Nov. 28, 2017) (holding that “there is no

clear statutory mandate . . . obligating [EPA] to evaluate or adjust . . . what entities are ‘appropriate[ly]’

forced to comply with” the annual renewable fuel

obligations (alterations in original) (quoting 42 U.S.C.

§ 7545(o)(3)(B)(ii)(I))). Accordingly, we conclude that

the meaning of “as appropriate” in paragraph (3) is

ambiguous and turn now to whether EPA’s construction is “based on a permissible construction of the

statute.” Chevron, 467 U.S. at 843.

The difficulty of squaring the Coffeyville Petitioners’

reading of “as appropriate” with the structure and

purpose of the statute convinces us of the reasonableness of EPA’s interpretation. As a structural matter,

the RFS program contains not only “annual” volumetric determinations, Conc. Op. 1, but also a slew of

compliance provisions that are not annually redetermined. As a practical matter, the point of

obligation is the foundational “compliance provision”

of the entire renewable fuels program; EPA could not

“ensure” that applicable volumes of renewable fuels

are introduced into the nation’s transportation fuel

supply without designating the parties responsible for

carrying the renewable fuel standards into operation.

Id. § 7545(o)(2)(A)(i). To that end, in writing the

compliance provisions, EPA placed the renewable fuel

obligation on the entities at the head of the United

States supply chain for nonrenewable fuels—domestic

51a

refiners, and importers of fuel refined elsewhere. See

72 Fed. Reg. at 23,923-24. After additional consideration, EPA in 2010 adhered to that decision. See 75 Fed.

Reg. at 14,721-22 (codified at 40 C.F.R. § 80.1406(a)(1));

see also Monroe Energy, 750 F.3d at 912. No one

challenged EPA’s decision in 2007 or 2010, and EPA

declined to revisit the issue in response to comments

in the 2017 annual rulemaking urging it to shift the

2017 point of obligation to blenders. See Response to

Comments at 542, Coffeyville J.A. 761.

The focus of the annual rulemakings, in contrast, is

to translate the applicable volumes—as specified in

paragraph (2), or set according to the process there

described—into percentage requirements for each

renewable fuel. 42 U.S.C. § 7545(o)(3)(B)(ii). It would

be strange indeed if Congress required EPA, as it went

about its annual quantitative standard-setting duties,

also to rethink a choice so basic to the RFS program’s

architecture. This implausibility is illuminated by the

fact that Congress required EPA to facilitate statutory

compliance through a credit trading program, which of

necessity requires some year-to-year stability. See id.

§ 7545(o)(5). EPA responded by setting up the RIN

system, with flexibility anchored to a fixed baseline—

the point of obligation. The compliance system is

flexible in that RINs may be retired in compliance

demonstrations not only in the compliance year during

which they were generated, but also throughout the

ensuing compliance year, 40 C.F.R. § 80.1427(a)(6),

and obligated parties may carry over excess RINs or

RIN deficits from year to year, id. § 80.1427(a)(1), (5)–

(6); see Monroe Energy, 750 F.3d at 913.

Annual changes to the point of obligation could

cause “disparities in RIN-holdings,” leaving formerly

obligated parties with “significantly more RINs,

52a

including carryover RINs, than they desire or can use”

and newly obligated parties with “lower balances than

they would desire to protect themselves against

shortfalls in RIN availability or RIN price volatility.”

EPA Denial at 78, Coffeyville J.A. 850. “[A] change to

the point of obligation could also cause volatility in the

[RIN] market,” inhibiting the “ability [of] parties that

possess excess carryover RINs to recover the cost of

the RINs they hold by selling them to other parties.”

Id. It is not plausible that Congress meant EPA to

consider uprooting the baseline of the RFS program

every year. The real stretch is that Congress would

have imposed such an onerous and potentially disruptive duty merely by use of the phrase “as appropriate.”

The Coffeyville Petitioners’ reading is not made any

more plausible by highlighting the likelihood that, on

annual consideration of the point of obligation, EPA

would only need to consider recent information, and

likely would stay its course. Even if the point of obligation in fact rarely changed, the mere “reconsider[ation]”

of the framework would “likely cause delays to the

investments necessary to expand the supply of

renewable fuels in the United States.” See EPA Denial

at 2, Coffeyville J.A. 774. EPA reasoned that “fuel[]

industry participants [would] withhold significant

investment decisions until the EPA’s final decision

and the fallout from the decision are known.” Id. at 8182, Coffeyville J.A. 853-54. Insisting that the issue be

on the regulatory agenda every year would sow

“significant market uncertainty and potential turmoil”

into the RFS program without offsetting benefit. Id.

Furthermore, any requirement that an agency

repeatedly go through a regulatory process on an issue

that promises to draw a regular parade of criticism

from interest groups with ample resources is itself

53a

burdensome. See AT&T Corp. v. FCC, 220 F.3d 607,

630-31 (D.C. Cir. 2000). This issue is no exception. As

discussed above, EPA in 2016 and 2017 considered and

decided against reopening its point of obligation rule.

In so doing, it received upwards of 18,000 comments

and published an exhaustive, 85-page decision. See

EPA Denial at 1-85, Coffeyville J.A. 771-857. “Given

the time pressure associated with its annual standards rulemaking,” EPA believes it would not be

feasible or worthwhile to undertake such reconsideration annually. Id. at 7 n.10, Coffeyville J.A. 779.

Indeed, as EPA acknowledged at oral argument, the

agency “has been late on [its annual rules] before,”

even “when [it hasn’t] taken up the point of obligation.” Rec. of Oral Arg. 1:25:44-52. “[A]dd[ing] on the”

duty to reassess the point of obligation annually, EPA

tells us, “would be a significant burden.” Id. at 1:25:551:26:05. Our colleague doubts that EPA’s year-to-year

burden would be appreciable, but we see no ground to

question EPA’s judgment to the contrary. It seems

unlikely that Congress wrote the applicability provision in order to heap that annual duty onto EPA’s

plate. It seems even less likely given the absence of

reason to think that yearly second-guessing of program fundamentals makes sense, or that, when and if

the need for a program restructuring arises, EPA

would fail to act. Indeed, the statute elsewhere explicitly requires EPA to conduct “periodic reviews of . . .

the feasibility of achieving compliance with the [applicable volume] requirements.” 42 U.S.C. § 7545(o)(11).

That provision has not been briefed, but would appear

to require EPA to reconsider the point of obligation if

it concluded that its placement was obstructing

compliance.

Finally, EPA’s approach coheres with basic principles of administrative law. In general, the choice

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between various procedural channels lies within the

“informed discretion of the administrative agency.”

SEC v. Chenery Corp., 332 U.S. 194, 203 (1947). That

discretion properly includes judgments about the scope

of rulemakings and when to relegate ancillary issues

to separate proceedings: “Agencies, like legislatures,

do not generally resolve massive problems in one fell

regulatory swoop.” Massachusetts, 549 U.S. at 524;

see, e.g., Grp. Against Smog & Pollution, 665 F.2d at

1292 (“. . . EPA cannot soundly be charged with arbitrariness merely because it chose a separate rulemaking

proceeding as the process for proposing a revised

standard in lieu of an undertaking to do so in the

narrower context of the opacity standard proceedings

as petitioners requested.”). Once the agency has resolved

an issue in a separate proceeding, it may defend

against related criticism by “simply refer[ing]” to the

other proceeding, so long as the “reasoning remains

applicable and adequately refutes the challenge.”

Bechtel v. FCC, 10 F.3d 875, 878 (D.C. Cir. 1993). EPA

reasonably reads “as appropriate,” in paragraph

(3)(B), to leave undisturbed these background norms

of broad but reviewable procedural discretion.

Our holding today does not give EPA the limitless

and unreviewable discretion feared by our colleague.

As we have said, EPA’s determination as to whether it

is “appropriate” to reconsider the point of obligation in

the context of an annual volumetric rulemaking is

reviewable for abuse of discretion. EPA did not abuse

its discretion in refusing to do so here. Indeed, it

considered whether to change the point of obligation

rule in a separate, contemporaneous proceeding that

yielded a final order that we also have reviewed and

found to be adequately justified. See supra Part IV.B.

We do not address whether it would be an abuse of

discretion for EPA to refuse to reconsider the point of

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obligation—in an annual volumetric rulemaking or

otherwise—in extreme circumstances akin to those

posited by our colleague’s hypothetical about the

continuing study of an abolished tort. See Conc. Op. 5.

In sum, we hold that EPA permissibly rejected the

claim that paragraph (3) requires the agency annually

to reassess the point of obligation in the renewable fuel

program. Because EPA has no duty to reconsider the

appropriateness of its point of obligation regulation as

part of its yearly determination of volumetric requirements, it was not arbitrary for EPA to treat comments

complaining that it obligated the wrong parties as

appropriately assessed in a separate proceeding, and

beyond the scope of proceedings for the 2017 volumetric rulemaking. For these reasons, we deny the

Coffeyville Petitioners’ petition.

B. Cellulosic Biofuel Projection

The Coffeyville Petitioners lob a variety of

challenges at EPA’s cellulosic biofuel projection for

2017. Many of these petitioners, however, raised many

of the same arguments before. See ACE, 864 F.3d at

727-29 (addressing challenges to EPA’s 2014-16 projection). We rejected those arguments once—and do so

again.

First, the Coffeyville Petitioners contend that

“EPA’s [m]ethodology” for projecting cellulosic biofuel

production is invalid because it “[c]hronically [o]verestimates [a]ctual [p]roduction.” Coffeyville Br. 40. But

that argument—that EPA has “repeatedly . . . overshot

the mark,” id. at 41—doesn’t apply to the methodology

EPA actually used here, as we found in ACE, 864 F.3d

at 727-28. As we explained when petitioners deployed

this same argument in challenging the 2014-16 projection, “the majority of EPA’s prior overestimations”

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utilized a different methodology—one that we rejected

in API, 706 F.3d at 478-81, and that the EPA

accordingly abandoned. ACE, 864 F.3d at 727. The

new methodology—the one EPA used here—has been

applied only twice before. At the time EPA made its

final evaluation for 2017, that methodology had (as

detailed in the table below) undershot for 2015 and

overshot for 2016. See Assessment of the Accuracy of

Cellulosic Biofuel Production Projections in 2015 and

2016, EPA-HQ-OAR-2016-0004-3687, at 1-4 (Dec. 12,

2016), Coffeyville J.A. 515-18. This is hardly a pattern

of chronic overestimation.

EPA

Actual

RFS

Record

Estimate Production EPA

Compliance

(millions (millions of Error ** Citation

Year

of RINs)

RINs)

Q1

2015

[No Data in the Record]

Q2

Q3

Q4

35.00

53.36

- 34.4%

J.A. 515

230.00

198.39*

+ 15.9%

J.A.

Q1

Q2

2016

Q3

Q4

* At the time of EPA’s assessment, the agency had

actual RIN production data for only the first nine

months of 2016 (123.99 million gallons). To calculate

actual production for the year, EPA extrapolated the

likely RIN generation for the last three months of the

year based on the historical relation (a multiple of 1.8)

between the average quarterly generation in the first

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three quarters and that of the last quarter, yielding a

figure of 74.39 million RINs for the last quarter. See

Coffeyville J.A. 51617.

** The EPA error has been calculated as the

difference between the EPA estimate and actual

production, divided by the actual production.

Second, the Coffeyville Petitioners claim that EPA

failed to generate a projection “based on” the cellulosic

biofuel estimate provided by the Energy Information

Administration (EIA), as required by statute. 42 U.S.C.

§ 7545(o)(7)(D)(i). That is so, they say, because 96% of

EPA’s projected volume was biogas, a type of cellulosic

biofuel that EIA did not include in its estimate. See

Coffeyville Br. 43-44. The problem for petitioners,

however, is that this closely parallels an argument we

rejected in ACE: “[W]e do not agree that EPA failed to

generate projections ‘based on’ the [EIA’s] estimates,”

even though those “estimates did not contain figures

for [biogas] production—production that accounts for

the vast majority of cellulosic biofuel” (“around 90

percent”). ACE, 864 F.3d at 724, 729. Here, as there,

EPA showed sufficient “respect” for EIA’s estimates.

Id. at 729. When limited to fuels actually analyzed by

EIA, EPA’s estimates were “very similar” to EIA’s, id.;

see 2017 Rule, 81 Fed. Reg. at 89,758/1, a fact that the

Coffeyville Petitioners do not contest.

Congress demanded no more. Nothing in the statute

required EPA to, as the Coffeyville Petitioners insist,

“work[] with the EIA to develop information” about

biogas. Coffeyville Br. 44. “[T]he Administrator of the

Energy Information Administration shall provide . . .

an estimate,” 42 U.S.C. § 7545(o)(3)(A), and EPA shall

“respect” it, API, 706 F.3d at 478. That’s it. In showing

such respect, EPA, of course, must “understand how

EIA derived” its estimate. Coffeyville Reply Br. 24.

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But, contrary to the Coffeyville Petitioners’ contention, EPA did just that. The agency identified the types

of cellulosic biofuels that EIA considered and then,

to test the integrity of its projection, conducted an

apples-to-apples comparison, “limiting the scope of

[its] projection to the companies assessed by EIA.” See

2017 Rule, 81 Fed. Reg. at 89,757-58. Nothing more

was required.

Third, the Coffeyville Petitioners object that EPA

relied on “information from the [biogas] industry”—an

industry “with a direct financial interest in the outcome of the rule.” Coffeyville Br. 45. The Petitioners

characterize this as “reliance on undisclosed information.” Id. But EPA did disclose the information

from the biogas industry—and that the information

came from that industry; it just did so in the aggregate. See October 2016 Assessment of Cellulosic

Biofuel Production from Biogas (2017), EPA-HQ-OAR2016-0004-3711, at 2-6 (Dec. 12, 2016), Coffeyville J.A.

536-40. All the agency withheld was company-specific

information, claiming that it had to withhold such

data as confidential business information, see id. at 7,

Coffeyville J.A. 541; see also 40 C.F.R. § 2.211(b), a

claim that petitioners never even attempt to rebut, see

Masias v. EPA, 906 F.3d 1069, 1077 (D.C. Cir. 2018)

(“It is not enough merely to mention a possible argument in the most skeletal way, leaving the court to do

counsel’s work . . . .” (quoting Schneider v. Kissinger,

412 F.3d 190, 200 n.1 (D.C. Cir. 2005))).

As for the implication of bias, we have previously

upheld EPA’s reliance on “biofuel producers’ own

forecasts.” ACE, 864 F.3d at 728; see also API, 706

F.3d at 478 (recognizing that producers are an “almost

inevitable source of information”). Here, as in ACE,

EPA did not “blindly adopt[] the facilities’ own

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forecasts”; it “performed its own investigation.” 864

F.3d at 728; see October 2016 Assessment of Cellulosic

Biofuel Production from Biogas, supra, at 4, Coffeyville

J.A. 538 (“To verify the reasonableness of these projections, EPA compared the projected volume from each

registered facility to the registered capacity of that

facility.”). Petitioners point to no unreasonable step by

EPA in its efforts to address “the uncertainty and

unreliability identified by the [Coffeyville] Petitioners.”

ACE, 864 F.3d at 728.

Fourth, the Coffeyville Petitioners protest EPA’s

reliance on “facilities’ actual production in prior years”

as a floor for projecting future cellulosic biofuel production. Coffeyville Br. 46. This was error, they say,

because some companies might cease production. Perhaps

so. But, as we said in ACE, although unforeseen issues

“could prevent a producer from meeting” its prior

year’s production, it was “reasonable” for EPA to

expect, as a general matter, “that a company’s output

would grow year-over-year as the company gained

experience.” 864 F.3d at 728. This seems especially

true in an industry with the government’s wind

surging at its back. And even were EPA’s assumption

not true for each company, any one facility’s shortfall,

EPA explained, could be “off-set” by new facilities

coming online or existing facilities exceeding the

high end of their projected production range. See

Renewable Fuel Standard Program—Standards for

2017 and Biomass-Based Diesel Volume for 2018:

Response to Comments, EPA-HQ-OAR-2016-0004-3753,

at 444 (Dec. 12, 2016), Coffeyville J.A. 707. This explanation fulfills EPA’s “duty to articulate a ‘reasonable

and reasonably explained’ approach to setting the low

end of the production ranges.” ACE, 864 F.3d at 729

(quoting Comtys. for a Better Env’t v. EPA, 748 F.3d

333, 335 (D.C. Cir. 2014)).

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Fifth, the Coffeyville Petitioners complain that EPA

should have based its cellulosic biofuel projections on

“actual” prior production. Coffeyville Br. 47. But this

backward looking approach would have, in EPA’s

view, “ignore[d] the potential for facilities . . . to

increase their fuel production rates” and would have

been “inappropriately conservative” in light of the

“year-over-year increases” that EPA had observed “in

recent years.” 2017 Rule, 81 Fed. Reg. at 89,761/1. We

cannot say that in rejecting such an approach EPA

violated “its duty to take a ‘neutral aim at accuracy.’”

ACE, 864 F.3d at 727 (quoting API, 706 F.3d at 476).

For these reasons, we reject the Coffeyville Petitioners’

challenges to EPA’s cellulosic biofuel projection for

2017. See ACE, 864 F.3d at 729.

C. Cellulosic Waiver

The Coffeyville Petitioners also challenge EPA’s

decision to use less than all of its discretionary cellulosic waiver authority to lower the 2017 requirements

for advanced biofuel and total renewable fuel. Having

reduced the 2017 cellulosic biofuel requirement by

5.189 billion gallons, EPA had authority to reduce the

advanced biofuel and total renewable fuel requirements “by the same or a lesser volume.” 42 U.S.C.

§ 7545(o)(7)(D)(i). To decide by how much to reduce

these statutory requirements, EPA first determines

what reduction in the advanced biofuel requirement

will yield a “reasonably attainable” volume, and it

then mechanically applies an equivalent reduction to

the total renewable fuel volume. 2017 Rule, 81 Fed.

Reg. at 89,752-53. Petitioners do not directly challenge

this methodology. Instead, they argue that EPA

applied it arbitrarily in deciding to waive only 4.719

billion gallons of the advanced biofuel volume for 2017,

rather than the maximum available waiver of 5.189

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billion gallons. We again reject some of their arguments as foreclosed by precedent and others on their

own terms.

First, the Coffeyville Petitioners argue that EPA

sought to justify its 2017 advanced biofuel volume in

part by making an impermissible comparison to the

statutory volume set by Congress for 2022. In response

to a comment expressing concerns about utilization of

non-cellulosic advanced biofuels (which could be

food-based) and possible adverse effects on food availability, EPA noted that its “reasonably attainable”

non-cellulosic advanced biofuel volume for 2017 (approximately 4 billion gallons) was “somewhat higher than

the level envisioned in the statute for 2017” (3.5

billion), “but well below the level of such fuels

Congress expected would be used by 2022” (5 billion).

Response to Comments at 214, Coffeyville J.A. 689.

According to petitioners, “by comparing 2017 volumes

with 2022 statutory targets, EPA departed from

Congress’s intent.” Coffeyville Br. 50.

However, nothing in the statute forbids EPA from

taking account of future statutory volumes in this way.

Although Congress specified presumptively applicable

volumes for certain years, it also provided waiver

authority to depart from those volumes. Indeed, the

discretionary waiver provision necessarily empowers

EPA to depart upward from the statutory level of noncellulosic advanced biofuel for a given year: reducing

the advanced biofuel volume by less than the reduction

in cellulosic biofuel, as section 7545(o)(7)(D)(i) permits,

is mathematically equivalent to increasing the volume

of non-cellulosic advanced biofuels, to “partially

backfill for missing cellulosic biofuel.” 2017 Rule, 81

Fed. Reg. at 89,763/1. As we have noted, the cellulosic

waiver provision “grants EPA ‘broad discretion’ to

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consider a variety of factors” in exercising this authority to depart from the presumptive statutory volumes.

ACE, 864 F.3d at 733 (quoting Monroe Energy, 750

F.3d at 915). In this case, while deflecting a comment

about food availability, EPA observed that its noncellulosic advanced biofuel volume for 2017—while

higher than the statutory volume envisioned for that

year—was lower than the presumptive statutory volume

for the near future. And it then reasonably concluded

that this “somewhat higher interim volume reflect[ed]

[its] assessment that it is appropriate to allow noncellulosic advanced biofuels to partially backfill for

missing cellulosic volumes in light of the associated

[greenhouse gas] and energy security benefits.” Response

to Comments at 214, Coffeyville J.A. 689.

Second, the Coffeyville Petitioners argue that EPA

failed to explain its estimate of reasonably attainable

2017 imports of sugarcane ethanol, a type of noncellulosic advanced biofuel. Sugarcane ethanol imports

have varied greatly from year to year, reaching a high

of 681 million gallons in 2006 but falling to 64 million

gallons in 2014 and 89 million gallons in 2015. See

2017 Rule, 81 Fed. Reg. at 89,764. At the time of the

2017 Rule, EPA expected only 76 million gallons to be

imported in 2016, but it nonetheless adhered to its

proposed estimate of 200 million gallons for 2017—

an estimate originally based on EPA’s judgment that

circumstances in 2017 were “not . . . significantly

different” from circumstances in 2016, for which EPA

had also projected 200 million gallons. Id. at 89,763/3.

EPA acknowledged the “recent low import levels,” but

also cited “the difficulty in precisely identifying the

reasons” for the historical “high variability,” given

“uncertainty” as to market factors including “ongoing

growth in gasoline demand in Brazil, and competing

world demand for sugar.” Id. at 89,764-65. The agency

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accordingly reaffirmed that 200 million gallons

“reflects a reasonable intermediate point between the

lower levels imported recently and the considerably

higher levels that have been achieved in earlier years.”

Id. at 89,765/2.

There is some force to petitioners’ objection to EPA’s

adherence to an estimate well over double the actual

imports in the three preceding years. However, our

review is “particularly deferential in matters implicating predictive judgments.” Music Choice v. Copyright

Royalty Bd., 774 F.3d 1000, 1015 (D.C. Cir. 2014)

(quoting Rural Cellular Ass’n v. FCC, 588 F.3d 1095,

1105 (D.C. Cir. 2009)). We accordingly upheld EPA’s

identical 2016 sugarcane ethanol estimate as “reasonable and reasonably explained” in ACE, 864 F.3d at

736 (quotation marks omitted). In that case, we held

that EPA reasonably “concluded that ‘a somewhat

lower level of imports will occur than the historic

average’ of 300 million,” based on a similar analysis of

market factors. Id. (quoting 2014-16 Rule, 80 Fed. Reg.

at 77,478/2). Here, we cannot say that one more year

of low imports made it arbitrary for EPA to adhere to

that same projection for 2017.

Third, the Coffeyville Petitioners object to EPA’s

analysis of supply and demand for regular gasoline

(E0) and gasoline with added ethanol (E15 and E85).

However, this analysis played no role in EPA’s exercise

of its discretionary cellulosic waiver authority under

section 7545(o)(7)(D)(i). As noted above, EPA’s exercise

of that authority rested entirely on its determination

of reasonably attainable advanced biofuel volumes.

See 2017 Rule, 81 Fed. Reg. at 89,773-74. The disputed

analysis of E0, E15, and E85 supported EPA’s separate

decision not to invoke its “general waiver” authority,

under section 7545(o)(7)(A)(ii), based on “inadequate

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domestic supply.” See generally ACE, 864 F.3d at 70513. But in their opening brief, petitioners failed to

challenge EPA’s decision not to invoke that separate

waiver provision for 2017. Although their reply brief

gestures at this point, “an argument first made in a

reply brief is forfeited.” Bartko v. SEC, 845 F.3d 1217,

1225 n.7 (D.C. Cir. 2017).

Finally, the Coffeyville Petitioners take issue with

EPA’s response to various comments. We have considered these arguments and find them to be without merit.

For these reasons, we reject the Coffeyville Petitioners’

challenges to EPA’s exercise of its discretionary

cellulosic waiver authority to reduce advanced biofuel

and total renewable fuel volumes for 2017.

VI. 2018 Volume for Biomass-Based Diesel

Since 2012, EPA, acting in coordination with the

Secretaries of Energy and Agriculture, has calculated

the annual applicable volume (also known as the

“volume requirement”) for biomass-based diesel based

on a holistic, backward- and forward-looking consideration of relevant factors. In particular, it has set

the volume requirement “based on a review of the

implementation of the program during calendar

years specified in the tables, and an analysis of” six

statutorily enumerated factors: (1) “the impact of the

production and use of renewable fuels on the environment”; (2) “the impact of renewable fuels on the energy

security of the United States”; (3) “the expected annual

rate of future commercial production of renewable

fuels, including advanced biofuels in each category

(cellulosic biofuel and biomass-based diesel)”; (4) “the

impact of renewable fuels on the infrastructure of the

United States”; (5) “the impact of the use of renewable

fuels on the cost to consumers of transportation fuel

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and on the cost to transport goods”; and (6) “the impact

of the use of renewable fuels on other factors, including

job creation, the price and supply of agricultural

commodities, rural economic development, and food

prices.” 42 U.S.C. § 7545 (o)(2)(B)(ii)(I)—(VI).

EPA set the 2018 applicable volume for biomassbased diesel at 2.1 billion gallons, up from 2.0 billion

gallons in 2017, and 1.1 billion gallons above a

statutory minimum that Congress set to plateau at 1

billion gallons as of 2012. 2017 Rule, 81 Fed. Reg. at

89,798/1; see 42 U.S.C. § 7545(o)(2)(B)(i)(IV), (v). NBB

had asked EPA to set the biomass-based diesel volume

at 2.5 billion gallons, and now challenges the volume

EPA set as arbitrary and capricious and contrary to

the Clean Air Act.

A. NBB’s Standing

Before considering the merits of NBB’s claims, we

must satisfy ourselves that NBB has standing to

assert them. Respondent-Intervenors, the American

Fuel & Petrochemical Manufacturers and the American

Petroleum Institute, contend that NBB lacks standing

because, they say, it has not shown that the 2017 Rule

inflicted a cognizable injury on any of its members.

NBB has associational standing here for the

same reasons we held it did in National Biodiesel

Board v. EPA, 843 F.3d 1010, 1015 (D.C. Cir. 2016)

(NBB v. EPA), where EPA’s actions “incentivize[d] . . .

compet[ition] with [NBB’s members’] domestic production.” Here, too, NBB’s members “compete with” the

other industry players EPA’s rule is designed to affect.

Id. at 1016. Recall that biomass-based diesel is a

nested subset of advanced and total renewable fuels,

such that NBB’s members get (1) a market for compelled buyers of the specified volume of biomass-based

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diesel, for which they are the exclusive suppliers, plus

(2) a market for compelled buyers of advanced and

other renewable fuels alongside a broad array of

competing suppliers. See supra at 6-8, 11. The 2017

Rule preamble explains that biomass-based diesel

“compet[es] for research and development dollars

with other types of advanced biofuels,” and that, “[b]y

establishing [the biomass-based diesel] volume requirement[] at [a] level[] lower than . . . the expected

production of [biomass-based diesel],” EPA was “creating

the potential for some competition between [biomassbased diesel] and other advanced biofuels to satisfy the

advanced biofuel” applicable volume and providing

“incentives for the continued development of” those

competitors’ fuels. 81 Fed. Reg. at 89,797; see also EPA

Coffeyville Br. 24 (“Above 2.1 billion gallons, biomassbased diesel will have to compete with other types

of advanced biofuel.”). Such competition will likely

“temper to some extent [biomass-based diesel] prices.”

Final Statutory Factors Assessment for the 2018

Biomass Based Diesel (BBD) Applicable Volume,

EPA-HQ-OAR-2016-0004-3708, at 10 (Dec. 12, 2016)

(Supplemental Assessment), Coffeyville J.A. 533. That

is a cognizable injury to NBB’s members. See NBB v.

EPA, 843 F.3d at 1015-16; see also Delta Constr. Co. v.

EPA, 783 F.3d 1291, 1299 (D.C. Cir. 2015) (per

curiam).

Though NBB failed to identify any of its members—

ordinarily a prerequisite for organizations alleging

associational standing, see Summers v. Earth Island

Inst., 555 U.S. 488, 497-98 (2009)—that omission is

not fatal here because NBB’s members comprise “the

entire biomass-based diesel category of the Renewable

Fuel Standard[s]” and represent no other interests.

Coffeyville J.A. 134. Consistent with “the real purpose

of the [standing] inquiry—that is, for the court to be

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satisfied that the requisite injury really has occurred

or will occur in the future to members of the organization[],” Pub. Citizen v. FTC, 869 F.2d 1541, 1552 (D.C.

Cir. 1989), there is no need to identify injured members when “all the members of the organization are

affected by the challenged activity,” Summers, 555

U.S. at 499 (citing NAACP v. Ala. ex rel. Patterson, 357

U.S. 449, 459 (1958)). Because EPA’s rule subjects the

biomass-based diesel industry to increased competition, with anticipated pricing effects, NBB “meet[s]

the constitutional prerequisites of injury, causation,

and redressability.” NBB v. EPA, 843 F.3d at 1015.

B. Merits of NBB’s Challenges

NBB advances two challenges to the applicable

volume EPA set for biomass-based diesel: First, that

EPA erred in considering the interaction of biomassbased diesel with the yet-to-be established 2018

advanced biofuel applicable volume, and second, that

EPA’s consideration of the six statutory factors was

arbitrary and capricious and contrary to law. We reject

both claims.

First, EPA reasonably chose a 2018 biomass-based

diesel applicable volume that would “maintain[] support

for growth in [biomass-based diesel] volumes” while

also encouraging the “development of other advanced

biofuels.” 2017 Rule, 81 Fed. Reg. at 89,798/1. Congress

directed EPA to consider the lessons learned from its

retrospective “review” of the program, apply them in

its prospective “analysis of” the six statutory factors,

and set a biomass-based diesel volume that will

apply fourteen months in the future. See 42 U.S.C.

§ 7545(o)(2)(B)(ii).

EPA’s approach is consistent with the structure and

purposes of the statute. Congress set a minimum

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applicable volume for biomass-based diesel of one

billion gallons for each year from 2012 forward, id.

§ 7545(o)(2)(B)(i)(IV), (v), while specifying statutory

minimum volumes for the advanced biofuel category

containing biomass-based diesel that grow year by year

to 21 billion gallons by 2022, id. § 7545(o)(2)(B)(i)(II),

(iii). EPA reasonably concluded that, by nesting

biomass-based diesel together with cellulosic (and

other unspecified) biofuels within the advanced biofuel

category, and specifically charting a higher, steeper,

and longer initial growth curve for advanced biofuel,

Congress anticipated that production of other types

of advanced biofuels could step up to help meet

the advanced biofuel volume requirement. See 2017

Rule, 81 Fed. Reg. at 89,797/1. EPA also reasonably

concluded that increasing fuel diversity serves one of

Congress’s primary goals in establishing the Renewable

Fuel Standards program: improving the nation’s

“energy independence and security.” See Pub. L. No.

110-140, preamble; see also 2017 Rule, 81 Fed. Reg.

at 89,798/3. EPA also reasonably anticipated that

enhanced competition in the advanced biofuels market

would help “temper to some extent [biomass-based

diesel] prices,” Supplemental Assessment 10, Coffeyville

J.A. 533, thereby ameliorating Congress’s concern

that, with a too-high target volume, the “price of biomassbased diesel fuel” would “increase significantly,” 42

U.S.C. § 7545(o)(7)(E)(ii). And fuel diversity may

produce environmental benefits insofar as certain

advanced biofuels, such as ethanol from food waste,

will “likely have significantly lower impacts on wetlands, ecosystems, and wildlife habitats” than would

greater reliance on biomass-based diesel. Supplemental

Assessment 6, Coffeyville J.A. 529.

NBB’s arguments to the contrary turn on reading

the statutory directive that EPA “review . . . the

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implementation of the program during calendar years

specified in the tables,” id. § 7545(o)(2)(B)(ii), to

confine EPA’s consideration to biomass-based diesel’s

statutory volumes and actual performance, and to

prevent EPA from considering other fuel categories or

future years. In particular, NBB takes issue with

EPA’s consideration of the not-yet-finalized 2018

advanced biofuel applicable volume, which NBB

contends led EPA to set the biomass-based diesel

volume too low.

NBB’s objections are not supported by the text or

purpose of the statute. Assuming NBB is right that

EPA’s “review of the implementation of the program”

consists of a retrospective assessment, the agency

must also conduct “an analysis of” six statutory factors.

Id. § 7545(o)(2)(B)(ii). And those factors plainly require

a prospective assessment—an assessment that would

likely miss “important aspects of the problem,” State

Farm, 463 U.S. at 43, if it ignored the interaction, now

and in the future, of the requirements for all the

categories of renewable fuels. See, e.g., 42 U.S.C.

§ 7545(o)(2)(B)(ii)(I) (requiring an “analysis of” the

“impact of the production and use of renewable fuels

on,” among other things, “the environment”). Though

EPA set the biomass-based diesel requirement lower

than NBB wished, Congress did not intend to incentivize growth of biomass-based diesel “at all costs.” ACE,

864 F.3d at 714 (quoting Am. Express Co. v. Italian

Colors Rest., 570 U.S. 228, 234 (2013)).

NBB objects that setting the 2018 biomass-based

diesel applicable volume below expected production

might lead to a depressed advanced biofuel volume for

2018. But the agency specifically anticipated “that the

2018 advanced biofuel requirement will be larger than

the 2017 advanced biofuel volume requirement.” 2017

70a

Rule, 81 Fed. Reg. at 89,798/1. EPA has never set

the biomass-based diesel applicable volume at the

“maximum potential production” level, id. at 89,799/3,

yet the “growing supply of” biomass-based diesel has

consistently “allowed EPA to establish higher advanced

biofuel” applicable volumes, id. at 89,797/3. EPA opted

for “allowing room within the advanced biofuel volume

requirement for the participation of non-[biomassbased diesel] advanced fuels” as a reasonable way

“to encourage the development and production of a

variety of advanced biofuels over the long term without reducing the incentive for [biomass-based diesel]

beyond the [biomass-based diesel applicable volume]

in 2018.” Id. at 89,797-98.

Second, in setting the 2018 biomass-based diesel

applicable volume, EPA reasonably compared the

advantages and disadvantages of biomass-based

diesel to those of other fuels. NBB contends that the

statute confines EPA to assessing advantages of

biomass-based diesel over petroleum, not considering

other renewable fuels, and that the agency failed to

“meaningfully” consider the six factors. NBB Br. 9-10.

Both arguments miss the mark.

NBB suggests that, because the statute “was

intended to ‘increase the production of clean renewable fuels’ as a substitute for petroleum fuel,” id. at 21

(quoting Pub. L. No. 110-140, preamble), the only

relevant comparison is to petroleum, not to other

categories of renewable fuel. But NBB identifies

nothing in section 7545(o)(2)(B)(ii) or any other section

that requires EPA to assess the performance of

a particular renewable solely by reference to petroleum fuel. Its analysis would require us to read

the term “renewable fuels” used throughout section

7545(o)(2)(B)(ii) to refer to the single renewable fuel

71a

being analyzed, even though the statutory definition

of “renewable fuel” includes all types of renewables.

See 42 U.S.C. § 7545(o)(1)(J). And if EPA could compare the benefits of each specific fuel only to petroleum, it might be unable to set rational applicable

volumes for each specified category of renewable fuel

after 2022, when the statute no longer sets any specific

volumes. See id. § 7545(o)(2)(B)(iii)—(v). EPA could

easily conclude, for example, that each renewable fuel

had a lower “impact . . . on the environment” than

petroleum fuel, see id. § 7545(o)(2)(B)(ii)(I), but, no

matter their differing merits in serving the statute’s

goals, the agency would be barred from making

relative judgments among renewable fuel categories.

NBB also argues that EPA failed to give meaningful

consideration to the six statutory factors, and instead

“pre-determined the outcome,” NBB Br. 20, but the

record shows otherwise. EPA considered in detail how

setting the biomass-based diesel applicable volume at

a level higher or lower than 2.1 billion gallons would

affect the six statutory factors. See 2017 Rule, 81 Fed.

Reg. at 89,798-99. EPA further elaborated its analysis

of the factors in an 11-page supplemental memorandum

evaluating effects of its proposed biomass-based

diesel volume on renewable fuel production rates, the

environment, and the economy. See Supplemental

Assessment 1-11, Coffeyville J.A. 524-34. EPA concluded that, over the long term, “[a] variety of different

types of advanced biofuels, rather than a single type

such as [biomass-based diesel], would positively impact

energy security . . . and increase the likelihood of the

development of lower cost advanced biofuels that meet

the same [greenhouse gas] reduction threshold as

[biomass-based diesel].” Supplemental Assessment 3,

Coffeyville J.A. 526. EPA thus concluded that the

statutory factors supported its biomass-based diesel

72a

applicable volume. See 2017 Rule, 81 Fed. Reg. at

89,798/3.

At bottom, NBB’s objections rest on a policy

disagreement: NBB urges that, instead of setting a

level that would support continued investment in the

biomass-based diesel industry while also encouraging

producers of other types of advanced biofuel to compete to satisfy the 2018 advanced biofuel applicable

volume at lower cost, EPA should have reserved to

biomass-based diesel alone a volume nearer to that

industry’s maximum production potential. But NBB’s

proposed “simple solution”—that EPA should have

“set[] a meaningful [biomass-based diesel] volume”

while planning to “increas[e] the 2018 advancedbiofuel volume to provide room for the production of

other advanced biofuels when it set that volume a year

later,” NBB Br. 23—describes what EPA actually did.

A mere disagreement with the particular calibration

of a line drawn in the exercise of an agency’s

reasonable judgment is no basis to invalidate a rule.

Therefore, we deny NBB’s petition.

VII. Conclusion

For these reasons, the petitions for review are

denied.

So ordered.

73a

WILLIAMS, Senior Circuit Judge, concurring in part

and concurring in the judgment:

The Clean Air Act’s Renewable Fuel Program operates

on an annual cycle. It provides annual credits, authorizes annual waivers, and calls for annual reviews, see,

e.g., 42 U.S.C. § 7545(o)(5), (7), (10)—all to implement

Congress’s annual goals, see id. § 7545(o)(2)(B).

Each year, as part of this annual affair, the Environmental Protection Agency embarks on an elaborate

rulemaking. Id. § 7545(o)(3)(B). In doing so, it receives

an annual estimate of the total volume of fuel to be

sold to inform it in setting the annual “renewable fuel

obligation,” id. § 7545(o)(B)(i), which “shall . . . be

applicable to refineries, blenders, and importers, as

appropriate,” id. § 7545(o)(3)(B)(ii)(I). So EPA is to

specify appropriateness among those three categories.

But “appropriate” as of when?

Coffeyville Petitioners say appropriate as of the

annual rulemaking.

But EPA says appropriate as of the last time EPA

happened to consider the issue, no matter how many

years earlier that was. The initial determination

sticks for “all years,” EPA says, “unless and until” EPA

chooses, in its “discretion,” to “undertake [an] annual

reevaluation[].” Denial of Petitions for Rulemaking to

Change the RFS Point of Obligation, EPA-HQ-OAR2016-0544-0525, at 7 (Mar. 13, 2018) (“EPA Denial”),

J.A. 779; see also EPA Br. 66 (claiming “discretion” to

decide “whether, how, and when” it will “reconsider its

initial designation”). Even when affected parties point

to a series of market “disparities” that they say have

developed and render the earlier determination “not

appropriate,” and point to § 7545(o)(3)(B)(ii)(I) as

entitling them to a fresh determination, see, e.g.,

74a

Valero Energy Corporation Comments, EPA-HQOAR-2016-0004-1746, at 1, 14 (July 11, 2016), J.A.

138, 151, EPA claims that that section does nothing

of the sort, see EPA Denial at 8, J.A. 780 (asserting

full “discretion” to decide “when” and “under what

circumstances” it will consider the issue). In Part V.A

of the court’s opinion, my colleagues accept EPA’s

theory. I, however, disagree. So while I otherwise join

the court’s opinion in full, I cannot joint Part V.A—

though I do, in the end, concur in the judgment.

* * *

At the risk of oversimplifying, we can boil this

annual process down to three steps.

First, the annual goal. Congress sets annual

(steadily increasing) goals for the volume of renewable

transportation fuel to be sold or introduced into

commerce in the United States, with special targets

for some subsets of renewable fuel. 42 U.S.C.

§ 7545(o)(2)(B)(i).

Next, the annual estimate. The Energy Information

Administration projects the total volume of transportation fuel that will be sold into commerce in a given

year (as well as volumes of biomass-based diesel and

cellulosic biofuel). 42 U.S.C. § 7545(o)(3)(A); see, e.g.,

Letter from Adam Sieminski, Administrator, U.S.

Energy Information Administration, to Gina McCarthy,

Administrator, U.S. Environmental Protection Agency,

EPA-HQ-OAR-2016-0004-3646 (Oct. 19, 2016), J.A.

494.

Finally, the annual obligation. This is set by EPA

during the agency’s annual rulemaking. And it is

expressed in terms of a single percentage of transportation fuel sold into commerce (the “renewable

fuel obligation”) by any obligated party (regardless

75a

of category). 42 U.S.C. § 7545(o)(3)(B)(ii); see, e.g.,

Renewable Fuel Standard Program: Standards for

2017 and Biomass-Based Diesel Volume for 2018, 81

Fed. Reg. 89,746, 89,751/3 (Dec. 12, 2016) (“2017

Rule”). The basic idea is this: If EPA knows (i) the

annual goal for the volume of renewable fuel introduced into commerce (see step one above), and (ii) the

annual estimate for the total volume of fuel to be

introduced into commerce (see step two above), then

EPA—after filling in any gaps in the goals left by

Congress, see 42 U.S.C. § 7545(o)(2)(B)(ii), and making

any necessary adjustments to the estimates provided

by the Energy Information Administration, see id.

§ 7545(o)(3)(A)—can set the minimum percentage of

renewable fuel that must be introduced into commerce

by “obligated parties.” If everything works out well,

Congress’s annual goal should, more or less, be met.

But who are these “obligated parties”? Under

the Act, EPA must tell us. The first among the

three “Required elements” of the annual determination is that it “be applicable to refineries,

blenders, and importers, as appropriate.” 42 U.S.C.

§ 7545(o)(3)(B)(ii)(I) (emphasis added).

Even though EPA “determine[s] and publish[es]”

the annual obligation anew “[e]ach [] calendar year[],”

42 U.S.C. § 7545(o)(3)(B)(i), since 2010 it hasn’t

considered what parties are “appropriate” to obligate.

Regulation of Rules and Fuel Additives, 75 Fed. Reg.

14,670, 14,722 (Mar. 26, 2010); see also Regulation

of Fuels and Fuel Additives, 72 Fed. Reg. 23,900,

23,923/2 (May 1, 2007). Rather, year in and year out,

the agency has simply “indicated,” “in passing,” that

the renewable fuel obligation “would apply to ‘. . .

producers and importers,’” “consistent with [its]

preexisting” determination. EPA Br. 69-70 (quoting

76a

2017 Rule, 81 Fed. Reg. at 89,746/2). That’s it. In my

view, however, the language of the statute requires

more. EPA’s contrary reading seems to me to go

unreasonably “beyond the meaning that the statute

can bear.” U.S. Postal Serv. v. Postal Regulatory

Comm’n, 886 F.3d 1253, 1255 (D.C. Cir. 2018) (quoting

MCI Telecomm. Corp. v. AT&T Co., 512 U.S. 218, 229

(1994)).

* * *

The key provision says, “[n]ot later than November

30 of each [] calendar year[],” EPA “shall determine

and publish in the Federal Register . . . the renewable

fuel obligation.” 42 U.S.C. § 7545(o)(3)(B)(i). The first

of the “Required elements” of that annual obligation is

that it shall “be applicable to refineries, blenders, and

importers, as appropriate.” Id. § 7545(o)(3)(B)(ii)(I).

This much tells us a few things. First, Congress

required EPA to set the renewable fuel obligation

annually. That feature of the requirement pretty

clearly indicates a congressional expectation of possible

year-to-year variation in all the mandatory elements—

not merely in the percentage chosen (which is addressed

in subclauses (II) and (III)). Second, one explicitly

required element of this annual determination is a

selection among “refineries, blenders and importers,”

a selection that must be “appropriate.” Taken together,

the Act seems inevitably to require EPA to apply (at

least) some thought to the issue of what market

sectors should be obligated—thought that the agency

must apply each time it sets the annual obligation.

After all, the term “appropriate” “naturally and

traditionally includes consideration of all the relevant

factors,” not just a recitation that some time ago the

agency considered the factors that it then thought

relevant. Michigan v. EPA, 135 S. Ct. 2699, 2707

77a

(2015) (emphasis added) (quoting White Stallion

Energy Center, LLC v. EPA, 748 F.3d 1222, 1266 (D.C.

Cir. 2014) (Kavanaugh, J., concurring in part and

dissenting in part)). The agency, in other words, must

“exercise its discretion to choose among the options”

that Congress has given it, Maj. op. 45 (quoting Kisor

v. Wilkie, 139 S. Ct. 2400, 2449 (2019) (Kavanaugh, J.,

concurring in the judgment)), not “explain[]” why, in

the agency’s opinion, it’s “appropriate” not to choose

among the options that Congress has given it, id.; see

Response to Comments, EPA-HQ-OAR-2016-00043753, at 542 (Dec. 12, 2016), J.A. 761 (declaring the

point-of-obligation “issue” “beyond the scope of this

rulemaking”).

Suppose a law school charter—adopted at the

school’s founding in 1920—calls on the dean to

annually set a “tort credits obligation,” consisting of a

minimum number of credit hours students must

devote to certain tort subjects; the dean is to make the

obligation “applicable to negligence, defamation,

battery, and alienation of affections, as appropriate.”

The first dean, in 1921, sets the obligation at three

credit hours per subject—and applies it to all the

subjects. For the 2020-21 academic year, the tenth

dean likewise duly requires students to devote at least

three credits hours to those same subjects including

alienation of affections. Students understandably

protest, since that tort is now a bygone relic. See Fitch

v. Valentine, 2005-CA-01800-SCT (¶¶ 79-81) (Miss.

2007) (Dickinson, J., concurring), 959 So. 2d 1012,

1036 (noting 31 states have “completely abolished” it).

But the dean adamantly refuses even to consider their

entreaties, “explain[ing]” (Maj. op. 45) they’re “beyond

the scope” (J.A. 761) of topics relevant to the annual

credit determination, which, after all, is perfectly

“consistent with [a] preexisting” 1921 determination

78a

that that application was “appropriate” (EPA Br. 70).

EPA’s reasoning (on the procedural point—whether or

not the phrase “applicable . . . as appropriate” requires

it to consider the issue) is, in essence, as startling as

the dean’s. Never mind whether, as a substantive

matter, studying the tort—or exempting blenders—is

actually “appropriate.” Cf. Maj. op. 52. EPA tells us it

need not even address the point—ever again.

EPA’s response does more to hurt than to help its

cause. The agency points us to similarities between the

provision we’ve been discussing, § 7545(o)(3)(B)(ii)(I),

and § 7545(o)(2)(A)(iii)(I), which I’ll call the “compliance provision.” The two echo each other, see Oral

Arg. Tr. 70:19–25, both using the “applicable . . . as

appropriate” formulation.

Annual determination, 42 U.S.C. § 7545(o)(3)(B)(i),

(ii)(I):

[E]ach . . . calendar year[] . . . , the

Administrator

of

the

Environmental

Protection Agency shall determine and

publish in the Federal Register . . . the

renewable fuel obligation . . . . The renewable

fuel obligation . . . shall . . . be applicable to

refineries, blenders, and importers, as

appropriate.

Compliance provision, 42 U.S.C. § 7545(o)(2)(A)(i),

(iii)(I):

Not later than [August 8, 2006], the Administrator shall promulgate regulations . . . .

[T]he regulations . . . shall contain compliance

provisions applicable to refineries, blenders, distributors, and importers, as appropriate . . . .

79a

As EPA reads the two, the agency may define

the point of obligation once—while announcing the

compliance provisions at the outset of the program.

See EPA Br. 66. Congress’s command to make the

annual renewable fuel obligation “applicable . . as

appropriate” is simply, in the agency’s view, a crossreference back to the “applicable . . . as appropriate”

determination made by EPA at the outset in its

adoption of compliance regulations. See, e.g., id. at 6970; Oral Arg. Tr. 70:19-71:15, 72:13-24, 73:16-74:13.

The agency’s reading, however, seems utterly

implausible. When Congress uses “identical words” in

“different parts of the same statute,” we normally infer

that those words carry “the same meaning.” Henson v.

Santander Consumer USA Inc., 137 S. Ct. 1718, 1723

(2017) (quoting IBP, Inc. v. Alvarez, 546 U.S. 21, 34

(2005)). So if “applicable . . . as appropriate,” in the

context of setting the compliance regulations, means

(as everyone agrees it means) that EPA is to contemporaneously assess the appropriateness of its decision,

then the same phrase, in the context of setting the

annual renewable fuel obligation, must mean the

same thing: EPA is to make a contemporaneous

assessment of appropriateness—rather than, as the

agency implausibly claims, treat a decision made long

ago as dispositive for the present.

The majority responds—somewhat bafflingly—that

nothing in the phrase “applicable . . . as appropriate”

indicates “when or in what context EPA must make the

appropriateness determination.” Maj. op. 46 (emphasis

added). But that can’t be right. Imagine a daycare

advertises that it will dress kids for recess, “as appropriate.” Would any reasonable speaker of English

really harbor any doubt as to whether there existed

a “particular temporal” connection between the

80a

selection made and the selection’s appropriateness?

Id. at 45. Surely parents would be surprised to learn

that the school’s clothing selection for a snowy,

December day was not “appropriate” in light of the

then-pounding blizzard, but, rather, was “appropriate”

in light of the sunshine from six months earlier, when

the daycare first opened.

In fact, had Congress wanted EPA to readopt a prior

determination, without any contemporaneous analysis as to appropriateness, “it could easily have chosen

clearer language” to do just that. NLRB v. SW General,

Inc., 137 S. Ct. 929, 939 (2017). Related provisions of

the same statute provide examples of such straightforward wording. An obvious possibility would be to

replace “applicable to refineries, blenders, and importers,

as appropriate,” with “applicable to Obligated Parties

(as defined by the Administrator under 42 U.S.C.

§ 7545(o)(2)),” thus using the pattern adopted in

§ 7545(h)(1), (k)(3)(B)(i). Another obvious way of expressing what EPA says Congress meant would have

been to modify “refineries, blenders, and importers”

with the phrase, “in conformity with the compliance

provisions established by the Administrator,” thus

paralleling the approach of § 7545(b)(2). Both formulations, relying on a past participle, easily invite the

construction that EPA prefers—allowing the administrator to rely on a decision made at some unspecified

time in the past. “The fact that [Congress] did not

adopt [any of these] readily available and apparent

alternative[s] strongly supports rejecting [EPA’s] reading.” Knight v. Commissioner, 552 U.S. 181, 188 (2008).

Further, rather than using such easy alternatives,

Congress chose language that, as read by EPA, makes

a mess of virtually all of § 7545(o)(3)(B)(ii). Again,

subclause (I) requires the “renewable fuel obligation”

81a

to “be applicable to refineries, blenders, and importers,

as appropriate.” 42 U.S.C. § 7545(o)(3)(B)(ii)(I). If

Congress had envisioned EPA “identif[ying] the

‘appropriate’ obligated parties” in its exercise of the

compliance provision (§ 7545(o)(2)(A)(iii)(I)), rather

than of this clause, as EPA says it did, see EPA Br. 7,

then subclause (I) would be doing no work at all—

contrary to the “principle of statutory construction

that we must ‘give effect, if possible, to every clause

and word of a statute,”‘ Williams v. Taylor, 529 U.S.

362, 404 (2000) (quoting United States v. Menasche,

348 U.S. 528, 538-39 (1955)).

EPA and the majority respond that subclause (I) is

needed to “clarify[]” that distributors—who can be

subjected to the compliance provisions—“cannot be”

subjected to the renewable fuel obligation. Oral Arg.

Tr. 75:9-12 (emphasis added); see also Maj. op. 47.

Compare 42 U.S.C. § 7545(o)(2)(A)(iii)(I) (providing

that the compliance provisions shall be “applicable to

refineries, blenders, distributors, and importers, as

appropriate” (emphasis added)), with id. §

7545(o)(3)(B)(ii)(I) (providing that the renewable fuel

obligation shall be “applicable to refineries, blenders,

and importers, as appropriate”). But the need for

clarity could be attributed to “most superfluous

language.” SW General, 137 S. Ct. at 941. And if clarity

were actually Congress’s goal, if all Congress wanted

to do in subclause (I) was exclude “distributors” from

the universe of potential obligated parties, Maj. op. 47,

it chose an exceedingly odd way of getting there:

inserting into an annual exercise the task of indicating

what entities are “appropriate” targets for the

renewable fuel obligation. Wouldn’t it have been more

straightforward to just reference EPA’s prior

determination, and then directly state—for the

82a

purpose of clarity—that the renewable fuel obligation

may not apply to “distributors”?

In any case, it’s hard to see what distributor-based

obscurity EPA sees a need for subclause (I) to correct.

Because the renewable fuel obligation concerns only

fuel that is “sold or introduced into commerce in

the United States,” 42 U.S.C. § 7545(o)(2)(A)(i),

(o)(3)(B)(ii)(II) (emphasis added), the obligation applies,

for any gallon of fuel, only once—i.e., when the fuel

enters the American economy upstream, not when

distributors transport the same fuel downstream.

Once the sale or introduction “into” commerce is

complete—once a given unit of fuel is already flowing

through American commerce—that same unit of

fuel cannot be sold or introduced “into” American

commerce again; it’s already there. While one, for

example, might say that a fuel line, which carries fuel

from a car’s tank to its engine, carries fuel “in” the car,

no one would say that it carries fuel “into” the car. So

too, while one might say that a distributor, which

transports fuel from the economy’s refineries to its

retailers, see 40 C.F.R. § 80.2(l); EPA Denial at 9, J.A.

781, transports fuel “in” the economy, no one would

say that it transports (or sells or introduces) fuel “into”

the economy; again, the fuel is already in the relevant

process. Congress itself recognizes the distinction, referring to fuel that is “sold or introduced into commerce,”

42 U.S.C. § 7545(o)(2)(A)(i), (o)(3)(B)(ii)(II) (emphasis

added), and fuel that is “sold or distributed in . . .

commerce,” id. § 7545(u)(4) (emphasis added). Because

distributors do only the latter—they move fuel “in,” not

“into,” commerce—there is nothing for subclause (I) to

clarify. These downstream intermediaries can never

fall within the universe of potentially obligated parties.

83a

My colleagues don’t claim to disagree; at most, they

declare it “non-obvious” that “distributors cannot be

subjected to the point of obligation.” Maj. op. 47. But

what’s “non-obvious” about it, even if we put the plain

meaning of “into commerce in the United States”

aside? That phrase appears throughout the statute—

and can’t possibly include downstream, distributor

transactions. Take the statutory provision concerning

the Energy Information Administration, which says

that the agency must provide EPA with an estimate

of the “volume[] of transportation fuel . . . projected

to be sold or introduced into commerce in the United

States.” 42 U.S.C. § 7545(o)(3)(A). Does Congress really

expect that estimate—and the regulatory burdens “based

on” that estimate, id. § 7545(o)(3)(B)(i), (o)(7)(D)(i)—to

radically fluctuate based on the frequency of transactions among the distributors that happen to line the

distribution network? So if every distributor starts

selling to another distributor, or several of them, the

calculated volume of fuel “sold or introduced into commerce in the United States” would balloon overnight?

I doubt it.

EPA, it seems, shares my skepticism. The agency

itself describes the renewable fuel obligation, not in

terms of downstream intermediaries, like distributors,

but in terms of the initial, upstream players—those

“responsible for introducing [fuel] into the domestic

gasoline pool.” 72 Fed. Reg. at 23,904/1 (emphasis

added). Indeed, when defining the renewable fuel

obligation, EPA speaks not of sales that happen to

occur, distributor-to-distributor, along the supply

chain, but only of initial injections into U.S. commerce

as a consequence of the upstream “produc[tion]” or

“import[ation]” of transportation fuel. 40 C.F.R.

§ 80.1407(a), (b).

84a

What about blenders, asks the majority? Aren’t they

potentially obligated parties, even though they, like

distributors, handle fuels that have already been

“introduce[d]” into U.S. commerce by other upstream

entities, like refineries? Maj. op. 46-47. Yes, of

course, they are. But that’s because blenders—unlike

distributors—are the ones who initially sell or introduce various types of finished transportation fuel “into

commerce in the United States.” E15, for instance, a

blend of 85% gasoline, 15% ethanol, generally enters

“into” American commerce at the hands of a blender—

the entity that actually blends the various components. Just ask EPA, which references the “ethanol

blenders that introduce E15 into commerce.” 76 Fed.

Reg. 44,406, 44,410/3 (July 25, 2011). A distributor, in

contrast—and by definition, whether that’s a “postenactment regulat[ory]” definition, Maj. op. 47, or a

pre-enactment dictionary definition—never introduces

anything “into” commerce. It only distributes (i.e.,

“transports” or “deliver[s]”) finished transportation

fuel, such as E15, from one point to another. See 40

C.F.R. § 80.2(l); Webster’s Third New International

Dictionary 660 (1961) (defining “distribute”). So subclause (I), as EPA reads it, is, in fact, a superfluity,

because the agency could not place the point of

obligation on distributors whether that clause existed

or not.

The muddle generated by EPA’s reading doesn’t end

there. Consider the effect on subclause (III). That

provision provides that the “renewable fuel obligation

. . . shall . . . consist of a single applicable percentage

that applies to all categories of persons specified in

subclause (I).” 42 U.S.C. § 7545(o)(3)(B)(ii)(III). But if

EPA is right, and the point of obligation is determined,

not under subclause (I), but under the compliance

provision, why does Congress take such a circuitous

85a

route to get there—a reference in subclause (III) to

subclause (I), which, in turn, in EPA’s reasoning (but

without linguistic underpinning), refers back to the

compliance provision? Couldn’t Congress in subclause

(III) have just alluded to decisions made by EPA under

the compliance provision directly? Cf., e.g., 42 U.S.C.

§ 7545(o)(4)(A). EPA doesn’t say.

Instead, the agency puts essentially all its eggs in

the compliance provision basket. EPA argues, first and

foremost, that its power to promulgate compliance

provisions is broad and includes the power to set the

point of obligation. And “nothing,” it says, requires it

to “reconsider” that determination. See, e.g., EPA Br.

67-68. My colleagues offer a similar thought, claiming

that Congress knew how to call for a “redo” if that is

what it really wanted. Maj. op. 48. Both arguments,

however, miss the point. When Congress mandates

an annual “determin[ation]” in 42 § 7545(o)(3)(B)(ii),

there is nothing to be redone or reviewed. The determination must happen anew each year, and the

specific instruction to apply that determination “to

refineries, blenders, and importers, as appropriate,”

controls, id. § 7545(o)(3)(B)(ii)(I); any general authorization to promulgate compliance provisions (including,

I’ll assume, license to not “reconsider” them) must

yield to that specific instruction. See SW General, 137

S. Ct. at 941 (“[I]t is a commonplace of statutory

construction that the specific governs the general.”

(alteration in original) (quoting RadLAX Gateway Hotel,

LLC v. Amalgamated Bank, 566 U.S. 639, 645 (2012)).

“[B]asic principles of administrative law,” unfortunately for the majority, only further erode EPA’s

position. Maj. op. 52. We “generally ‘presume[] that

Congress expects it statutes to be read in conformity

with the[] [Supreme] Court’s precedents.’” Porter v.

86a

Nussle, 534 U.S. 516, 528 (2002) (second alteration in

original) (quoting United States v. Wells, 519 U.S. 482,

495 (1997)). And those precedents make clear that an

agency, when exercising its congressionally delegated

authority, must “consider [every] important aspect of

the problem.” Motor Vehicle Mfrs. Ass’n of US. v. State

Farm Mutual Ins. Co., 463 U.S. 29, 43 (1983). Failure

to do so “would be arbitrary and capricious.” Id. With

that background in mind, it “would be strange indeed”

if Congress really expected EPA, year in and year out,

to set the renewable fuel standards for the entire

economy, yet allowed the agency—sub silentio—to

do so without considering ever again whether a

“foundational” element of the regulatory program was

“appropriate.” Maj. op. 49.

Retreating from the statutory language, EPA claims

that reading the Act to require it to appropriately

identify the point of obligation each year would be

inconsistent with Congress’s “purpose.” Specifically,

the agency says, it would “reduce the regulatory

certainty required for private parties to plan for

growth.” EPA Br. 72. But EPA’s fears are vastly

overblown. Its concern about upsetting investmentbacked expectations is a reason to not change the point

of obligation; it is not a reason to not consider doing so.

The same goes for my colleagues’ concerns about the

credit trading program, see Maj. op. 50, even if that

program really does require (as my colleagues seem to

assume it does) rock solid stability in the point of

obligation—a dubious proposition, given that credits

are held individual-entity-by-individual-entity, so that

shrinkage or swelling of the number of covered entities

has no impact on the needed computations. EPA’s

duty is to “articulate a satisfactory explanation for its

action,” State Farm, 463 U.S. at 43—an explanation

that must consider the industry’s (including the credit

87a

traders’) reliance on a prior determination, see, e.g.,

FCC v. Fox Television Stations, Inc., 556 U.S. 502, 515

(2009) (explaining that it “would be arbitrary and

capricious to ignore” the fact that a “prior policy has

engendered serious reliance interests”); Nat’l Cable &

Telecomms. Ass’n v. FCC, 567 F.3d 659, 670 (D.C. Cir.

2009) (similar). In fact, given the substantial reliance

interests at stake, along with the agency’s prior findings, it seems likely that (in the absence of significantly

changed circumstances or a compelling new analysis)

EPA would be able to make rather short work of the

annual analysis. In most years, the prior analyses and

the reliance interests would probably dictate the

conclusion.

In any event, especially when the alleged downside

of petitioners’ claim is so chimerical, our “role is not to

‘correct’ the [statutory] text so that it better serves

[Congress’s] purposes.” Va. Dep’t of Medical Assistance

Servs. v. U.S. Dep’t of Health & Human Servs., 678

F.3d 918, 926 (D.C. Cir. 2012) (some internal quotation marks omitted) (quoting Engine Manufacturers

Ass’n v. EPA, 88 F.3d 1075, 1089 (D.C. Cir. 1996)).

That is a job for Congress.

For these reasons, I respectfully disagree with the

panel’s conclusion, which grants EPA essentially

unfettered discretion as to when—or even if—it will

consider the appropriateness of the point of obligation.

Indeed, the panel, it seems to me, arrived at its

conclusion only by extending to EPA the type of

“reflexive” deference that the Supreme Court has

recently criticized. Kisor, 139 S. Ct. at 2415 (quoting

Pereira v. Sessions, 138 S. Ct. 2105, 2120 (2018)

(Kennedy, J., concurring)). The Court has made clear

that before we may declare a statute genuinely

ambiguous—and, thus, before we, an Article III court,

88a

may surrender to an executive agency’s (often selfserving) declaration of what the law means—we must

exhaust all the “traditional tools” of statutory construction. Kisor, 139 S. Ct. at 2415 (quoting Chevron

U.S.A. Inc. v. Natural Resources Defense Council, Inc.,

467 U.S. 837, 843 n.9 (1984)). Then and only then—

“when that legal toolkit is empty”—may we “wave the

ambiguity flag.” Id.

The majority, however, in apparent haste to bow to

EPA’s admittedly self-serving declaration of what the

law means, see Maj. op. 51 (describing the “burden[s]”

that EPA would rather avoid), doesn’t actually use any

of the tools of statutory construction in an attempt to

discern Congress’s meaning. For example, besides

acknowledging that EPA’s reading of the phrase

“applicable . . . as appropriate” “is not ineluctable,”

Maj. op. 48, the majority has almost nothing to say

about that phrase’s ordinary meaning. Although the

majority declares it “ambiguous,” id. at 49, my

colleagues do not offer a single example of the phrase

being used in the way EPA desires—where the duty to

make a selection, “as appropriate,” (somehow) permits

the decisionmaker wholly to ignore the contemporaneous context of his selection. But see supra pp. 5, 7

(offering examples where EPA’s interpretation makes

no sense). The majority’s treatment of the presumption of consistent usage isn’t much better. It says that

there are multiple “permissible” ways to ascribe the

same meaning to the same words, but doesn’t offer

any, see Maj. op. 46—all the while overlooking an

obvious interpretation that satisfies the presumption

(i.e., EPA must consider the factors that are relevant

at the time of its decision), see supra pp. 6-7. Finally,

the majority writes off the canon against surplusage

without actually finding that the language at issue

isn’t superfluous. The majority avers that a finding

89a

of superfluity “rests on a complicated series of

inferences,” Maj. op. 47, but that’s not unusual, or

reason to shy away from wading through the muddle.

Complex regulatory schemes “can sometimes make

the eyes glaze over. But hard interpretive conundrums,

even relating to complex rules, can often be solved.”

Kisor, 139 S. Ct. at 2415. To solve such conundrums,

however, we must embrace the canons of interpretation as the useful tools that they are for discerning

Congress’s meaning, not as pests to be dodged and

swatted away in our rush to deference. Here, when

those tools are properly applied, we can discern

Congress’s meaning—which “is the law and must be

given effect.” Chevron, 467 U.S. at 843 n.9.

Nonetheless, I concur in the judgment. As we

explain today with regard to claims brought by the

Alon Petitioners, EPA adequately explained, at

around the time it set the annual obligation for 2017,

why it was not “appropriate” (in light of the facts as

they then existed) to change the point of obligation.

See Maj. op., Part IV.B. Although that explanation

arose in the context of a petition for rulemaking—and

was thus subject to a more deferential form of

arbitrary and capricious review—I would hold here

(for the same reasons that we give in Part IV.B of the

majority opinion) that EPA’s reasoning was sufficient

even under the deference level that demands more of

the agency.

The difference in our standard of review between an

appeal from the agency’s annual determination under

§ 7545(o)(3)(B)(i), (ii)(I), on the one hand, and an

agency’s conventional duty to entertain a petition for

a rulemaking to revise an existing regulation, on the

other, is in practice fairly slight. Under both understandings, the agency is bound to give suitable weight

90a

to reliance interests, and indeed to the general

advantage of regulators’ not rocking too many boats. A

party challenging the status quo faces some sort of

burden in either context—to point to new facts, or to

new discoveries of facts, or to previously unnoticed

flaws in the agency’s analysis, etc. There is, to be sure,

a subtle difference in the deference level, but deference

levels themselves build in a good deal of subjectivity. I

nonetheless write separately because I see Congress

as having imposed a specific, if modest, duty, on the

agency, and having thereby provided an explicit

avenue for review. That explicitness seems to me

designed to, and likely to, concentrate the mind of the

administrator—a congressional choice that we should

honor.

91a

APPENDIX B

UNITED STATES COURT OF APPEALS

FOR THE DISTRICT OF COLUMBIA CIRCUIT

————

No. 17-1258

————

Consolidated with 18-1027, 18-1040, 18-1041

————

AMERICAN FUEL & PETROCHEMICAL MANUFACTURERS,

Petitioner,

v.

ENVIRONMENTAL PROTECTION AGENCY,

Respondent,

SMALL RETAILERS COALITION, et al.,

Intervenors.

————

On Petitions for Review of an Action of the

United States Environmental Protection Agency

————

Argued February 20, 2019

Decided September 6, 2019

————

Thomas A. Lorenzen and Samara L. Kline argued

the causes for Obligated Petitioners. Suzanne Murray

argued the cause for petitioner-intervenor Small Retailers

Coalition. With them on the briefs were Julie R.

Domike, Michael J. Scanlon, Richard S. Moskowitz,

Robert J. Meyers, Elizabeth B. Dawson, Megan H.

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Berge, Lisa M. Jaeger, Brittany M. Pemberton, and Clara

Poffenberger. Evan A. Young entered an appearance.

Bryan M. Killian argued the cause for petitioner

National Biodiesel Board. With him on the briefs was

Douglas A. Hastings.

Devorah Ancel argued the cause for Environmental

Petitioners. With her on the briefs was Eric Huber.

Benjamin R. Carlisle, Attorney, and Michael R.

Eitel, Senior Trial Attorney, U.S. Department of

Justice, argued the causes for respondent. With them

on the brief were Jeffrey H. Wood, Acting Assistant

Attorney General, Jonathan D. Brightbill, Deputy

Assistant Attorney General, and David P. W. Orlin,

Attorney, U.S. Environmental Protection Agency.

Thomas Allen Lorenzen argued the cause for intervenors in support of respondent responding to National

Biodiesel Board. With him on the brief were Robert A.

Long Jr., Kevin King, Stacy Linden, Richard S.

Moskowitz, Robert J. Meyers, and Elizabeth B.

Dawson. David Y. Chung and John P. Wagner entered

appearances.

Seth P. Waxman, David M. Lehn, Saurabh Sanghvi,

Claire H. Chung, Robert A. Long, Jr., Kevin King,

Matthew W. Morrison, Bryan M. Stockton, Bryan M.

Killian, and Douglas A. Hastings were on the brief

for intervenors Growth Energy, et al. in support of

respondent.

Matthew W. Morrison, Bryan M. Stockman, Seth P.

Waxman, David M. Lehn, Saurabh Sanghvi, Claire H.

Chung, Bryan M. Killian, and Douglas A. Hastings

were on the brief for intervenors Renewable Fuels

Association, et al. in support of respondent.

93a

Before: HENDERSON, TATEL, and GRIFFITH, Circuit

Judges.

Opinion for the Court filed PER CURIAM.

PER CURIAM: The Clean Air Act’s Renewable Fuel

Program mandates that certain amounts of renewable

fuel must be introduced into the U.S. fuel supply each

year. In late 2017, the EPA promulgated its final 2018

Rule, which, as in previous years, established overall

targets for the fuel market and imposed individual

compliance obligations on fuel refineries and importers.

These consolidated cases concern various challenges to

the 2018 Rule. Several petitioners maintain it is too

strict, others allege it is too lax, and still others argue

that the EPA failed to follow proper procedures in its

promulgation. We conclude that all these challenges

lack merit, except for one: that the EPA violated its

obligations under the Endangered Species Act by

failing to determine whether the 2018 Rule may affect

endangered species or critical habitat. We therefore

grant the petition for review filed by the Gulf

Restoration Network and Sierra Club and remand the

2018 Rule without vacatur for the EPA to comply with

the Endangered Species Act. We deny all other

petitions for review.

I. Background

A. The Renewable Fuel Program

Enacted in 2005 and amended in 2007, the Renewable

Fuel Program (the “Program” or “RFS Program”),

alternatively called the Renewable Fuel Standard,

was designed “[t]o move the United States toward

greater energy independence and security” and “to

increase the production of clean renewable fuels.”

Energy Independence and Security Act of 2007, Pub.

L. No. 110-140, pmbl., 121 Stat. 1492, 1492; see also

94a

id. §§ 201–210 (amending the Program); Energy Policy

Act of 2005, Pub. L. No. 109-58, § 1501, 119 Stat. 594,

1067-76 (enacting the Program). To accomplish these

goals, the Program regulates suppliers through “applicable volume[s]”—mandatory and annually increasing

quantities of renewable fuels that must be “introduced

into commerce in the United States” each year—and

tasks the EPA Administrator with “ensur[ing]” that those

annual targets are met. 42 U.S.C. § 7545(o)(2)(A)(i). As

we explained in Americans for Clean Energy v. EPA,

“[b]y requiring upstream market participants . . . to

introduce increasing volumes of renewable fuel into

the transportation fuel supply, Congress intended the

Renewable Fuel Program to be a ‘market forcing

policy’ that would create ‘demand pressure to increase

consumption’ of renewable fuel.” 864 F.3d 691, 705 (D.C.

Cir. 2017) (first quoting Renewable Fuel Standard

Program: Standards for 2014, 2015, and 2016 and

Biomass-Based Diesel Volume for 2017, 80 Fe

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