National Energy & Fuels Institute said it filed “two major comment letters” with the U.S. Environmental Protection Agency, addressing how heating oil is treated under the Renewable Fuel Standard (RFS) and another dealing with proposed regulatory reforms to expedite natural gas pipeline expansion. The letters follow recent testimony by NEFI President and CEO Jim Collura before the agency and ongoing engagement with senior administration officials, the Institute reported in its newsletter, NEFI Energy Online News. Following is the text of the letters, edited for clarity and length.
The Aug. 8 letter commenting on proposed changes to treatment of heating oil under the RFS, slightly edited for clarity and length, reads in part:
NEFI strongly supports the proposed increase in volumes for biomass-based diesel and advanced biofuels for compliance years 2026 and 2027 under the Renewable Fuel Standard (RFS) program. Our association agrees with EPA’s assessment that there is ample capacity and more than adequate feedstock availability to meet the proposed volume requirements in the years to come.
In its 2019 Providence Resolution, the heating oil industry voluntarily pledged to reduce emissions through increased use of biofuels to support American farmers, enhance energy diversity and security, and meet consumer demand for cleaner fuels. Several state governments in the Northeast have recognized the benefits of biodiesel-blended heating oil and now require minimum blends statewide. As of July 1, 2025, these requirements are 10 percent in Connecticut and New York and 20 percent in Rhode Island, affecting more than 1.9 million households and requiring around 160 million gallons of biomass-based diesel (BBD) for minimum compliance in an average winter. This does not include retailers who blend above these amounts in these states or that blend on a discretionary basis in states without similar requirements. Note as well that these fuels are used primarily during the winter months, when transportation fuel demand is lowest, providing year-round stability for American feedstock growers and biofuel producers.
The RFS is key to ensuring the availability of these fuels at competitive prices, enabling the heating oil industry to meet its voluntary commitments, comply with state blending requirements , remain competitive in an ever-changing market, and respond to growing demand for cleaner, American-produced fuels from customers – and to do so in a cost-effective manner that benefits small businesses and working families. Given this, NEFI is supportive of the higher renewable volume obligations (RVOs) for BBD.
However, we are deeply concerned with proposed changes that could undermine 15 years of successful policy. EPA’s proposed changes with respect to the definition of “heating oil” and the newly proposed definition of “renewable fuel oil” threaten to impose burdensome and impractical requirements that could harm our mostly small family businesses and increase home heating costs for millions of American families. Congress recognized
the fungibility of biofuels that can be used in transportation fuel and in residential heating applications. For 15 years, EPA has correctly allowed RIN generation for heating oil used in both residential space heating and water heating—consistent with Congressional intent. The proposed definitional changes appear unduly restrictive, which would be a significant and unexplained departure from established policy that must be addressed. To support its goals of increasing American biofuel use and strengthening energy independence , Congress provided that biofuel used in space and water heating applications can contribute toward meeting the RFS volume requirements. To meet Congress’s goals, EPA’s implementation of the RFS program should support increased use of biofuels in this market, rather than restrict such use through overly burdensome requirements that could disincentivize producers from supplying the heating oil market, thereby reducing supply, potentially increasing prices, and undermining the innovative efforts our industry has made to rise to Congress’s challenge.
Claiming it is merely “clarifying” the regulations regarding the use of the terms “heating oil” and “renewable fuel oil,” EPA’s proposed rule creates confusion and could impose undue restrictions on the use of biofuels in the heating oil market. Indeed, we believe some of the claimed “technical corrections” could be read as making significant changes to the current regulations without explanation and in violation of the notice and comment requirements of the Clean Air Act. As such, NEFI urges EPA not to finalize the proposed revisions to the heating oil definition or those related to its proposed new definition of “renewable fuel oil.”
NEFI has been a strong supporter of the growth of biofuels to support American farmers and rural economies , enhance energy reliability and affordability, meet growing demand for cleaner fuels, and promote American energy dominance. Biodiesel, renewable diesel, renewable propane, and other advanced biofuels provide our mostly small family businesses with the opportunity to help achieve state and federal goals while enhancing their own competitiveness and preserving a future for themselves in the evolving energy economy. The RFS program has been key to supporting the growth of biofuel use in the heating oil market. When implemented properly, it has also led to reduced prices for consumers , as RIN values can be passed down to customers in the form of savings.
Continued growth and success of biofuel use in the heating oil industry
depends on sound federal policy that reduces – not increases – regulatory burdens. Wholesale and retail marketers of these fuels are looking for assurances from the agency that it is serious about promoting deployment of larger volumes and higher blends of biofuels. Robust implementation of the RFS is one area in which the administration can signal this commitment and thereby inject confidence into the entire value chain, from farmers and biofuel producers all the way down to American homeowners and Main Street businesses. The heating oil market can accommodate extremely high concentrations of biofuels into its fuel supply. America’s residential heating oil market serves 4.79 million households with a robust infrastructure that has demonstrated the capacity to handle billions of gallons annually. Approximately four billion gallons were used in the most recent winter of 2024-2025.
Also consider that in most cases, homeowners can utilize blends of 20% (B20) or higher with nominal system modification, achieving superior environmental performance without costly heating system conversions.
Because of the outsized role heating oil plays in the Northeast relative to other parts of the country, our industry has become an essential partner as states and localities look to fulfill their goals of reducing emissions without increasing household energy costs. Indeed, states throughout the Northeast and Mid-Atlantic regions have enacted or are actively considering an array of policies to require or incentivize increased use of biofuels in the heating oil sector. The RFS helps ensure these American-produced fuels can compete dollar-for-dollar against petroleum fuel and incentivizes fuel suppliers and distributors to invest in related infrastructure and supplant conventional heating oil with biodiesel or other advanced biofuels. Thus, to further the goals of Congress and this administration’s commitment to unleashing American energy, NEFI supports the proposed increases in the volume requirements for biomass-based diesel but strongly opposes the proposed changes to the definition of “heating oil” and the new definition of “renewable fuel oil.” The proposed regulatory changes make significant changes to the regulations that the heating oil industry has been operating under for 15 years without explanation beyond a claim that EPA is “clarifying” requirements. But the proposed regulatory language could be read to impose burdensome requirements on fuels that have long been used in the heating oil market and to restrict innovation in the sector, moving backwards from the advances the industry has made to incorporate biofuels into “home heating oil” as Congress provided and intended.
Imagine asking millions of American homeowners to sign affidavits about their heating oil use – this is the type of impractical burden these changes could impose. We further urge EPA to revise the regulations related to fuels used in the heating oil market to ensure sufficient availability and choice and to continue to support innovation and growing volumes of American biofuels for use in the heating oil market.
…Additionally, NEFI aligns itself with comments submitted by the Advanced Biofuels Association (ABFA) regarding EPA’s proposed 50 percent RIN discount for foreign fuels and domestic fuels produced from foreign feedstocks. This provision would further constrain access to renewable fuel supplies in the Northeast, particularly given our geographic constraints. The Northeast liquid fuels market relies heavily on waterborne fuel delivery and is distant from regions where most domestic feedstocks and biofuels are produced.
Moreover, as ABFA notes, the recently enacted One Big Beautiful Bill (PL 119-21) already provides substantial incentives for domestic feedstock use, making EPA’s proposed RIN discount both redundant and counterproductive. Trade policy tools are better suited to address concerns about foreign competition while preserving the flexibility needed for effective negotiations with trading partners. The RIN discount would result in substantial market uncertainty and disruption and potentially increase fuel costs for our members and their customers. NEFI urges EPA to withdraw this provision entirely and allow existing tax incentives and trade policy to address domestic production priorities.
Here, slightly edited for clarity and length, is the Aug. 6 NEFI letter to EPA, commenting on proposed reforms to expedite natural gas pipeline expansion:
We are closely monitoring the debate over Section 401 [of the Clean Water Act] and evaluating its impact on our industry, especially its role in preventing or delaying the buildout of new natural gas pipelines in New York and New England. With respect to this matter, there is a recurring misconception used to justify these projects and the broader need for Section 401 reforms: that more natural gas is needed to displace so-called “dirty” home heating oil in the Northeast. Respectfully, this view is outdated and misleading . These comments serve to address this misinformation.
The transformation of our industry over the past decade represents one of the most successful environmental achievements in the energy sector, driven largely by private-sector innovation rather than government mandates. Since 2012, Northeast states from Maryland to Maine, where 85 percent of the nation’s home heating oil is used, averaging four billion gallons annually, have transitioned to ultra-low sulfur heating oil (ULSHO) with a sulfur content of 15 parts per million (ppm) or less. This shift has achieved a 99 percent reduction in sulfur content and sulfur dioxide emissions relative to earlier benchmarks, while effectively eliminating particulate emissions , which are primarily sulfate-based.
Research from Brookhaven National Laboratory confirms that ULSHO systems are engineered for “Zero Smoke” performance, rendering them roughly as clean as natural gas. Additionally, the dramatic sulfur reduction minimizes buildup within heating systems, promoting cleaner, safer, and more efficient operation. Modern high-efficiency liquid-fuel-fired systems dramatically outperform older equipment, offering potential fuel savings of 25 to 30 percent or more.
Our industry has also led the way in integrating renewable fuels into residential oilheat. Blending ULSHO with advanced biofuels such as biodiesel or renewable diesel lowers greenhouse gas emissions, supports American agriculture, enhances regional energy security, and diversifies the Northeast’s energy mix. These fuels are compatible with existing infrastructure, enabling households and businesses to transition to cleaner energy without costly system conversions.
Equipment manufacturers have responded to these advances with remarkable innovation. Underwriters Laboratories updated its UL 296 Standard in 2022 to include liquid fuel-fired burners designed for use with biodiesel blends ranging from 20 to 100 percent . Major manufacturers, including R.W. Beckett Corporation and Carlin Combustion Technology, now offer burners compatible with up to 100 percent biodiesel or renewable diesel. Energy Kinetics has announced UL-listed burners for its full line of residential heat and hot water boilers, rated for 100 percent biodiesel (B100). These systems can utilize indoor fuel tanks where cold weather performance is not a concern. For outdoor installations, modern cold flow additives effectively address gelling concerns, countering outdated misconceptions about biodiesel reliability. Beyond biodiesel, renewable diesel is gaining ground in our market, and innovative cellulosic feedstocks are advancing. For example , Ethyl Levulinate (EL), developed by Biofine Developments Northeast, is a net-negative emissions biofuel derived from waste biomass, including sawmill byproducts, forest residues, and the cellulosic fraction of municipal solid waste. This supports sustainable forestry management and reduces landfill waste. Taken together, these advanced fuels reflect the industry’s ongoing innovation in leveraging existing infrastructure to achieve lower emissions, improved system reliability, and reduced energy costs.
Utilization of renewable liquid heating fuels by our industry helps ensure year-round demand for American biofuels, which supports farmers, creates good-paying jobs, and strengthens rural economies. When transportation-related use of biofuels drops in winter, our demand peaks, creating stable markets that keep biofuel producers and feedstock growers viable all year long. This countercyclical demand pattern provides essential economic stability for American agriculture at a time when farm incomes face significant pressure.
NEFI members are Main Street businesses deeply embedded in their communities. Some are so trusted, they literally hold keys to their customers’ homes. They employ tens of thousands of good-paying American jobs including heating fuel delivery drivers and service technicians who show up in the worst weather conditions and are always ready to respond to a “no heat” call, whether it be at night, on weekends, or even Christmas or New Year’s Eve.
NEFI recognizes the need for a diverse energy mix that includes all fuels and technologies, especially in the energy-constrained Northeast. Like the rest of the country, Northeast states can expect unprecedented growth in electricity demand due to data centers, artificial intelligence computing requirements, and the onshoring of manufacturing driven by the administration’s trade policies. As a result, we expect that most additional natural gas capacity entering the Northeast through expanded pipeline infrastructure will likely be purchased and consumed by power generators, technology companies operating data centers, and large commercial and industrial end users. The reality is that firms advocating natural gas pipeline expansion are primarily motivated by the need for more electrons, not home heating oil conversions.
We support removing unnecessary regulatory and permitting barriers that would allow Americans greater access to the fuels of their choice while enhancing energy security and reliability. Home heating oil can and should be part of that diverse energy mix. We urge support for a level playing field that allows all fuels and technologies to compete on their merits and ensures consumers have access to the energy that is right for their families.
As the discussion of Section 401 moves forward and its role in Northeast pipeline expansion is reevaluated, we ask that the Administration and EPA consider the facts about today’s heating oil: clean, renewable, and delivered by trusted local businesses. The characterization of heating oil as “dirty” or environmentally inferior is not merely inaccurate. It undermines farmers and businesses large and small that have invested billions of dollars in environmental and efficiency improvements, threatens to distort energy policy decisions, and misleads the 12 million Americans who rely on heating oil for warmth and comfort each winter.
When EPA evaluates the scope of Section 401 certification and considers how states assess water quality impacts, we urge the Agency to ensure that all energy sources are evaluated based on current technology and actual emissions profiles, not outdated assumptions. Modern liquid heating fuels have achieved dramatic reductions in particulate and sulfur emissions and continue to advance through renewable blending. These improvements should be recognized in any comparative analysis of energy options.
Furthermore, the heating oil industry’s distributed storage model provides essential resilience to the Northeast energy system. With millions of households maintaining on-site fuel storage, our customers reduce strain on the electric grid during peak winter demand periods. This decentralized approach enhances energy security, particularly during extreme weather events when pipeline capacity constraints or power outages threaten other energy delivery systems.
As EPA considers potential guidance or rulemaking regarding Section 401 implementation, we respectfully offer the following recommendations:
First, the Agency should ensure that Section 401 reviews are based on accurate, current information about all energy sources. Decisions based on outdated characterizations of heating oil and related technologies do a disservice to consumers and undermine market competition.
Second, EPA should recognize that energy diversity strengthens regional resilience and national security. Preserving access to multiple energy sources, including ultra-low sulfur heating oil and its renewable blends, protects consumer choice, embraces free market competition, and reduces systemic risk from overreliance on any single energy delivery system.
Third, any reforms to Section 401 implementation should consider impacts on small businesses throughout the energy supply chain. Our members and their employees deserve regulatory certainty that allows them to continue investing in cleaner technologies and serving their customers and communities.
Finally, we encourage EPA to support continued innovation in renewable fuel development. The success of biodiesel and renewable diesel in the heating oil market demonstrates that market-driven solutions can achieve significant environmental improvements without requiring costly infrastructure overhauls or stranding existing assets.
The transformation of the heating oil industry demonstrates that American innovation and small business ingenuity can deliver both environmental progress and energy security. As EPA shapes policy regarding Section 401 implementation, we encourage the Agency to base decisions on current technology and performance rather than outdated assumptions. We are not asking for special treatment, just accurate representation in these critical policy discussions and a seat at the table as the administration takes action to ensure a new era of American energy leadership.
In closing, NEFI looks forward to working with you to ensure Americans have access to safe, reliable, and affordable energy while supporting the small businesses that form the backbone of energy distribution in the Northeast.