The 2021 and 2022 proposed RVOs, developed by EPA, have been under review at the Office of Management and Budget (OMB) for a week. As we reported last Friday, the proposal was sent from EPA for review last Thursday. What is in the proposal is still a mystery, however. That differs from last year; the proposed volumes for 2021 were submitted to OMB in May during the COVID pandemic and the volumes were fairly transparent with EPA giving a “heads-up” to the industry, though they were never published even for public comment.

While the process has not been transparent this year, there are various rumors and speculation about what might be in the proposed rule. Following is a look back at the RVO process in 2013-2016 to try to find...