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Coalition for Renewable Natural Gas v. EPA — D.C. Cir. (Oct 13, 2026)

No. 25-1183 Argued October 13, 2026 Published October 14, 2026

The D.C. Circuit hears challenges to EPA's reduction of the 2024 cellulosic biofuel requirement. Under the Renewable Fuel Standard, refiners and fuel importers must meet annual renewable-fuel obligations. Cellulosic biofuel is a category that includes qualifying renewable natural gas used for transportation. Compliance is tracked through RINs, tradeable credits associated with qualifying fuel. EPA set the 2024 requirement in 2023, then lowered it in a rule published in July 2025, citing a shortfall. The fuel-production year was already over. The Coalition for Renewable Natural Gas will challenge that after-the-fact change. Jonathan Ellis, of McGuireWoods, will argue that it undercut the certainty producers relied on when investing. Daniel Martin of the Justice Department will defend EPA's view that the law requires a reduction when production falls below the target, even after the deadline. The American Fuel and Petrochemical Manufacturers, represented by Elizabeth Dawson, will initially support EPA's reduction. But that group also wants further relief, including for unmet obligations carried over from 2023. Later in the hearing, Dawson will challenge EPA's refusal to reduce the requirement further. You will also hear about cellulosic waiver credits. Unlike RINs generated from qualifying fuel, these credits are offered by EPA as another way to satisfy the cellulosic obligation; they are not fuel produced.

Coalition for Renewable Natural Gas v. EPA (No. 25-1183) — U.S. Court of Appeals for the D.C. Circuit, argued October 13, 2026.

Sources
Argument audio — official D.C. Circuit joint hearing:https://media.cadc.uscourts.gov/recordings/docs/2026/10/25-1183.mp3
Case, counsel and argument date — official D.C. Circuit recording index:https://media.cadc.uscourts.gov/recordings/bydate/2026/10
Coalition's objections and investment background — September 4, 2025 reconsideration petition, introductory pages:https://www.epa.gov/system/files/documents/2026-01/rfs-rng-coalition-petition-2025-0904.pdf
Manufacturers' waiver request and prior-year deficits — November 1, 2024 AFPM petition, pages1–4 and8–9:https://www.epa.gov/system/files/documents/2024-11/afpm-rfs-cellulosic-waiver-petition-2024-11-01.pdf
EPA's waiver reasoning and treatment of deficits — June 2025 response to comments, sections1,2 and4.1:https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P101HUJV.pdf
RIN compliance credits — U.S. Department of Energy explanation:https://afdc.energy.gov/laws/RIN.html
Cellulosic fuel category — U.S. Department of Energy explanation:https://afdc.energy.gov/data/10423

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