As we have reported on both 6 August and 13 August, EPA is finalizing rules for the 2014 required volume obligations (RVO) for biofuels, and there is much speculation on how EPA will handle setting RVOs that fit within the 13.2 billion gallon blend wall for ethanol and fall within the EPA's regulatory jurisdiction under the statute (i.e., the 2005 Energy Policy Act and the 2007 Energy Independence and Security Act). EPA does have some waiver authority to lower the standards but they are limited.The goal is to get the 18.15 billion gallons provided by the statute this year (see below) down to what EPA calls a reasonably achievable target.The easiest waiver is the cellulosic category. EPA has the ability to waive the cellulosic ethanol requ...