Unintended consequences

Posted by Dobrien 7 years, 7 months ago to Economics
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HOLLYFRONTIER's
President and CEO George J Damiris
From Q2 2016 earnings call transcript

Also impacting earnings this quarter were increasing costs associated with purchasing RINs to comply with the RFS mandate, which in this margin environment continue to have significant impact as a proportion of earnings.

Before I discuss operational results and expectations, I'd like to spend a moment on the RFS program. Obviously, this mandate has been receiving increased attention in recent months, given the price of RINs and negative blending economics. We believe the constructs of the RFS do not align the ability to influence biofuel blending with the burden of compliance.

Along with others in our industry and our trade association, AFPM, we're advocating for the EPA to address this mismatch in the point of obligation and to do so expeditiously. The simple fact is that RINs were intended to be a certificate of compliance under the RFS, not a method of extracting value or creating winners and losers based on asset configuration in the value chain.

A far more equitable structure would be to expand the point of obligation to include those parties that have the ability and desire to increase volumes of biofuel blending as of the intent of the RFS. Further, we agree with those advocating for oversight of the RIN market. We believe oversight is needed to regulate speculatory participation, which has caused RIN prices to trade well in excess of the cost of blend in a market that is thinly traded and where demand for RINs has already pegged against supply.

The current point of obligation carries severe unintended consequences for merchant refiners like HollyFrontier, and does not advance goals set forth by the EPA. We believe the mismatch between the burden of compliance and the ability to influence biofuel blending is becoming more understood in Washington, by other affected parties and by EPA officials. We ask that EPA move quickly in their analysis of the point of obligation and, ideally, initiate a rulemaking process that will provide the quickest path to implementing an equitable solution.


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  • Posted by DrZarkov99 7 years, 7 months ago
    It appears that none of the current generation of government bureaucrats have ever been taught the rule of diminishing returns. There is a tipping point beyond which no amount of regulation will produce a significant improvement in performance, and the cost of compliance will exceed the imagined gains.

    One glaring current example is a new DOT rule under consideration restricting the speed limit of trucks on major roadways, supposedly to reduce accidents. With over 30,000 highway deaths a year, the reduced speed will supposedly reduce the body count by under a hundred fatalities annually. Of course, the analysis ignored a possible increase in fatalities from collisions rear ending slower moving trucks, and did not consider the possibility that slower speed would inevitably result in truckers spending longer hours behind the wheel, increasing the risk of accidents. Economic impacts were also unidimensional, citing reduced fuel costs at the lower speed, but not the likely costs of increased truck fleet size to meet delivery schedules, just to cite one likely result.
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  • Posted by $ allosaur 7 years, 7 months ago
    If I had the power, me dino woulda given all EPA personnel two weeks notice to find other jobs during the Twentieth Century. There has been way enough heightened environmental awareness to shift that responsibility back to states, counties and towns.
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    • Posted by $ jdg 7 years, 7 months ago
      EPA's job doesn't even need to be done. The air and water are clean enough and the earth is not in danger.

      But even if it did, EPA has no constitutional authority to exist. (And arguably neither does any administrative agency. I would overturn the entire Code of Federal Regulations as a violation of separation of powers.)

      Programs like the one described are not "ponzi schemes" but they are rent-seeking schemes, and thus destroy wealth for no gain. David Friedman explains rent-seeking in Hidden Order.
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      • Posted by $ allosaur 7 years, 7 months ago
        If I had the power, I would fire everything else that has no constitutional authority to exist also.
        I would amend that amendment that pertains to the IRS also.
        I am dino~
        Hear me ROAR!
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    • Posted by 7 years, 7 months ago
      Hi Dino,
      Countless times
      I have heard he or she is not for clean water or air.
      This candidate is against education. This one is against women. What a bunch of bullshit. There are very few humans that would be opposed to air water education or women.
      Have a great weekend and roll tide.
      DOB
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      • Posted by $ allosaur 7 years, 7 months ago
        For the longest time Sean Hannity kept replaying O the Great and Powerful Liar saying "Republicans are for dirty air, dirty water" on his radio show.
        Yeah, like any political party, even the Communist Party, would want their kids to have all dirty that.
        And more than once I've seen msnbc termite Chris Hayes run an hour long show entitled "War On Women" where channel-surfer Old Dino could spot it in a corner of the screen. What a doofus!
        And with a sigh of relief my Roll Tide great weekend begins.
        At one point Ole Miss was ahead of Bama 24-to-3. But that nail-biter ended with Bama 48 and Ole Miss 43. Bama has a history of pulling off wins like that.
        ROLL TIDE! WHOOPEE!
        Ahem, hope you have a great weekend too, DOB
        Old Dino
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        • Posted by 7 years, 7 months ago
          91 points that sounds like my golf scores. Exciting game for the Allosaur , hope you enjoyed a basket of pterodactyl wings with the win. Tonight I witnessed the rise of the full Harvest moon, great show as it appears many times larger on the horizon in the east.
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          • Posted by $ allosaur 7 years, 7 months ago
            More like refrigerated leftover pork chops with just as leftover brown rice mixed up with field peas all zapped together on a plate in a microwave.
            I saw that harvest moon rise last night.
            Today its been overcast with a light rain all day, which is unusual this time of year where I live.
            It was a pretty day during the game in Oxford, Mississippi. Guess that nice weather will drift over here tomorrow so I can get another look at that harvest moon .
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  • Posted by Herb7734 7 years, 7 months ago
    What can anyone say? It's pure, blatant, hypocritical, looting. People are so used to getting screwed over that they no longer even bother to protest or even get upset.
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    • Posted by 7 years, 7 months ago
      Hi Herb7734
      It's just accepted that we sacrifice the individual or industry (coal, refining ,mining, lumber) for the greater good. But whose greater good that is where it will always fail.
      Regards,
      DOB
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      • Posted by Herb7734 7 years, 7 months ago
        SO>>>>what is the greatest good? Why, it's whatever the state says it is. That's the very foundation of collectivism. Pretty obvious to us. not so with leftys. "They are also blind who will not see."
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  • Posted by chad 7 years, 7 months ago
    What?? Without some comments to enlighten me on the subject at reading the original statement I had no idea of what was being addressed. Adjusting speed limits as under Jimmney Carter did nothing to reduce the number of deaths on the highway. Most are caused by reckless choices made by drivers and does not change with speed limits. As far as what additives or amounts of other 'fuels' have to be used in order to satisfy someone's imagined environmental impact free people will by a majority approve (by purchase) what is best for their needs which in turn will be what is best for the environment. What really does not make sense is to sell the right to do what is antithetical to the regulation, what is important? To obey or to purchase the right to sin? If anyone knows of a place where a man can live free let me know, I will be on my way.
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    • Posted by 7 years, 7 months ago
      Hi Chad,
      Non elected govt bureaucraps creating expense and chaos in the market place with no rhyme or reason.A real co.s thoughts and consequences to it of EPA meddling
      Regards,
      DOB
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      • Posted by chad 7 years, 7 months ago
        As far as unintended consequences socialist bureaucrats intend to create the consequences we are getting. An unintended consequence for them is when they accidentally create more control (havoc) than intended, then it is bonus time.
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  • Posted by 7 years, 7 months ago
    Renewable identification numbers (RINs) are credits used for compliance, and are the “currency” of the RFS program.
    •Renewable fuel producers generate RINs
    •Market participants trade RINs
    •Obligated parties obtain and then ultimately retire RINs for compliance

    RINs can be traded in two forms:
    •Assigned RINs - directly associated with a batch of fuel and that travel with that batch of fuel from party to party. Purchase obtain both the renewable fuel and RINs together.
    •Separated RINs - formerly assigned with a batch of fuel, but are no longer assigned to a batch. Purchase only the RIN.

    Examples of typical RIN transactions include:
    •Generate - when a fuel is produced, a RIN is generated
    •Buy - when an assigned/separated RIN is bought/traded to by a buyer from a seller
    •Sell - when an assigned/separated RIN is sold/traded by a seller to a buyer
    •Separate - when a RIN is separated from the fuel to which it was originally assigned
    •Retire - when a RIN is used to demonstrate compliance, or required to be retired for other purposes

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    Market Participants

    The regulations outline the following types of RIN market participant categories:
    •Obligated parties (refiners and importers of gasoline or diesel)
    •Renewable fuel exporters
    •Renewable fuel producers
    •Registered RIN market participants

    Participants include both domestic and foreign companies. A company may fall under one or more categories and can change from year to year based on their trading or business activities.

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    RIN Transactions in EMTS

    EPA moderated transaction system (EMTS) is a database of record for all transactions involving RINs.
    •Parties enter into a trade agreement outside of EMTS
    •Each of the trading partners then enter into EMTS a separate record (“buy”/”sell”)
    •EMTS matches the trades; if the QA check is passed RINs are transferred between accounts

    Companies maintain RIN accounts by D-codes and RIN year (typically called “vintage” year, or the year in which the RIN was generated). RINs are retired for compliance by obligated parties and exporters based on their RVO.
    •Obligated parties typically only retire RINs after the end of the compliance year (or by March 31st)
    •Exporters have to retire RINs for compliance within one month of the export event (this was a recent change in 2014).

    RINs not retired for compliance can be carried over into the next compliance year. RINs are only good for satisfying obligations for the current compliance year or the following compliance year. For example, 2012 RINs can only be used for 2012 and 2013 compliance years. After that, the RINs “expire” or can no longer be used for compliance purposes.
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