Why It Matters

The Renewable Fuels Association has filed a new lobbying registration disclosure with H&M Strategies LLP, expanding its federal lobbying footprint as Congress and the EPA wrestle with a series of consequential decisions for the ethanol industry.

The RFA has maintained an in-house lobbying operation for years, with staff lobbyists filing congressional lobbying filings on fuel standards, tax credits, and trade policy. Bringing in an outside firm signals an effort to add capacity at a moment when several high-stakes policy fights are converging simultaneously. The RFA's new federal lobbying registration lists the fuel, gas, and oil issue area, consistent with the organization's longstanding priorities.

By the Numbers

The RFA has historically handled its lobbying in-house. Over the past year, three lobbying disclosure forms were filed under the RFA's own name, covering a broad range of issues from the Renewable Fuel Standard to sustainable aviation fuel and international trade barriers.

The new registration adds H&M Strategies LLP to that roster. The firm's portfolio is diverse, representing clients including Toyota Motor Corp., AARP Inc., Intel Corp., and Aurora Operations Inc., among others. H&M Strategies generated roughly $3.36 million in lobbying revenue across its client base over the past year.

Two lobbyists are listed on the RFA's lobbying registration disclosure: Kristen Bautz and Sarah Walter.

The Agenda

The new registration lists the Fuel/Gas/Oil issue code, but does not specify particular legislation or issues. Based on the RFA's prior lobbying disclosure forms, the organization has lobbied extensively on:

  • The Renewable Fuel Standard and small refinery waivers
  • Year-round E15 availability
  • The 45Z Clean Fuel Production Tax Credit
  • Sustainable Aviation Fuel policy
  • International trade barriers on ethanol, including tariffs from Brazil, China, India, and Colombia
  • The Farm Bill and climate-smart agriculture

One bill directly relevant to the RFA's core priorities is H.R. 1346, the Nationwide Consumer and Fuel Retailer Choice Act of 2025, which the RFA has previously lobbied on. A companion Senate measure, S. 593, has been referred to the Senate Committee on Environment and Public Works.

Broader Context

Several regulatory and legislative developments have unfolded in recent months that are directly relevant to the RFA's lobbying activity.

On the regulatory front, the EPA finalized volume requirements under the Renewable Fuel Standard for 2026 and 2027, with a final rule published in the Federal Register on April 1, 2026. The rule includes a 70 percent reallocation of small refinery exemptions granted for 2023 through 2025, a provision the ethanol industry has long pushed for.

On E15, the EPA approved year-round sales of the higher-ethanol blend in eight Midwestern states beginning in 2025. The RFA welcomed the change but publicly criticized a delay in implementation. The RFA said at the time: "While we are pleased to see EPA has finally approved year-round E15 in these eight states, we are extremely disappointed by the agency's needless decision to delay implementation until 2025." The RFA has continued to push for a national expansion of that access.

On tax policy, the 45Z Clean Fuel Production Credit took effect January 1, 2025, replacing the prior 40B sustainable aviation fuel credit. The credit is authorized through 2027 and applies to transportation fuels with low lifecycle greenhouse gas emissions. H.R. 1, the so-called "One Big Beautiful Bill," proposed expanding the 45Z credit for conventional biofuels while reducing it for sustainable aviation fuel, according to an analysis by the Clean Air Task Force.

On trade, Brazil has pushed back against potential U.S. tariffs on Brazilian ethanol, with its energy minister calling such a move unreasonable. The RFA has praised the Trump administration's counter-tariff actions toward Brazil, which the White House cited in connection with a U.S.-Brazil ethanol trade imbalance.

Between the Lines

Congressional activity on renewable fuels has been substantial in the period leading up to this lobbying registration disclosure.

H.R. 1346 passed the House on April 29, 2026, the same day the RFA's new registration was signed. The bill would extend the Reid Vapor Pressure waiver currently applicable to E10 gasoline to cover E15, effectively enabling year-round nationwide E15 sales. It has 48 House cosponsors and a Senate companion with 20 cosponsors.

In March 2026, the Senate Commerce Committee held a hearing on increasing domestic consumption of U.S.-grown agricultural products, at which witnesses from the National Corn Growers Association and National Farmers Union testified on E15, the Renewable Fuel Standard, and the 45Z credit. In April 2026, the House Ways and Means Committee held a hearing on trade policy at which Rep. Randy Feenstra questioned the U.S. Trade Representative about ethanol export opportunities. USTR Jamieson Greer responded that the U.S. had secured agreements with several countries to reduce tariffs on U.S. ethanol imports, including opening what he described as a billion-liter market with the UK.

Member communications have also reflected sustained engagement with the RFA's issue areas. Rep. Zach Nunn introduced a resolution designating May 2025 as Renewable Fuels Month. Sen. Amy Klobuchar visited an ethanol facility in March 2026 to advocate for year-round E15. Sen. Richard Durbin discussed biofuels and E15 access in April 2026.

Competitive Landscape

The RFA is not the only organization lobbying on renewable fuels and related tax credits. The broader ethanol and biofuels industry includes groups such as Growth Energy, the American Coalition for Ethanol, and the National Corn Growers Association, all of which have been active on E15, the RFS, and the 45Z credit. The congressional communications data shows Growth Energy was mentioned in member communications from both Rep. Mike Bost and Sen. Durbin in early 2026, reflecting its parallel advocacy on year-round E15.

The Bottom Line

The RFA's new lobbying registration disclosure with H&M Strategies comes at a moment when the ethanol industry faces a full legislative and regulatory agenda. The 45Z credit is set to expire in 2027. The RFS volume rules have been newly finalized. H.R. 1346 has passed the House. Trade negotiations with Brazil remain unresolved. Adding outside lobbying capacity reflects the breadth of that agenda, not a single pressure point.

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