Small Refinery Exemptions under the Renewable Fuel Standard: Historical Trends and the 2026 Decisions

This report examines historical trends in Small Refinery Exemption (SRE) petitions and exemption decisions from 2011 to 2025 and evaluates the magnitude and potential implications of the U.S. Environmental Protection Agency's (EPA) 2026 decisions. Using EPA administrative records and published U.S. Renewable Fuel Standard (RFS) standards, we document changes in petition outcomes, quantify exempted obligations relative to national renewable fuel requirements, and adjust for changes in annual RFS percentage standards to assess the evolution of exemption magnitude over time. Results indicate that annual petition volume remained relatively stable, ranging from 26 to 44 petitions, while adjudicated approval rates varied substantially. After declining to approximately 30% during 2013-2015, approval rates remained between 70% and 97% from 2016 onward. The magnitude of exemptions increased considerably, with the approximately 1.76 billion Renewable Identification Numbers (RINs) exempted for the 2025 compliance year representing 7.95% of the projected national renewable volume obligation, the second-highest share on record. Moreover, after accounting for changes in RFS percentage standards, the average exempted obligation per full-exemption equivalent increased from approximately 244 million gallons of gasoline and diesel in 2013 to 570 million gallons in 2025.