Hollyfrontier Cheyenne Refining, LLC v. Renewable Fuels Assn. (20-472)

argument 20-472

Hollyfrontier Cheyenne Refining, LLC v. Renewable Fuels Assn.

Supreme Court of the United States 1h 39m 8 speakers 8 chapters transcribed 6 days ago official recording ↗

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What is the central legal question about the Renewable Fuels Standard in this case?

John G. Roberts 0:00

We will hear argument first this morning in case 2472, Holly Frontier Cheyenne Refining versus Renewable Fuels Association. Mr. Keisler.

Unknown 0:12

Mr. Chief Justice, and may it please the Court, the statute establishing the Renewable Fuels Standard exempted all small refineries from its requirements for the first years of the program and authorizes them individually to seek extensions of that exemption at any time based on hardship. The question here is whether it prohibits EPA from granting a hardship exemption to a small refinery that hasn't been continuously exempt for all prior years. Respondents claim it does. Under their view, a small refinery can receive exemptions indefinitely, but only if it's never able to comply without hardship. If there's even one year in which it can comply without hardship, it's then disqualified for all future years.

Unknown 0:54

Nothing in the statute's text imposes this unique prohibition. Respondents' argument rests on the word extension, which they contend should be read temporally here to mean an increase in a length of time. But even if extension is read in its temporal sense, that does not require continuity. No dictionary defines extension to require continuity, and Congress has used the term elsewhere when it's specifically authorizing the temporal resumption of a benefit after a lapse. And where Congress has wanted to limit the term in the way respondents urge, it's added limiting words like successive or consecutive, which it didn't do here. A continuity requirement would also be contrary to this statute's purposes.

Unknown 1:37

The statutory design is to impose burdens that escalate dramatically over time. As the Department of Energy explained in 2011, some small refineries will face inherent and disproportionate hardships that will only arise or that will increase as those mandates grow. driving those small refineries out of the market would undermine the statute's energy independence goals, and that's one of the reasons Congress authorized them to petition at any time based on hardship. I welcome the Court's questions.

John G. Roberts 2:08

Mr. Keisler, under your reading, which extend means to grant, you know, you extend an offer or extend condolences, could an entirely new refinery apply for an extension to it of a hardship exemption? In other words, coming onto the scene for the first time and they would, under your view, I think, have to ask for an extension?

Unknown 2:34

Yes, Mr. Chief Justice. If the court adopted the make-available meaning of extension, then yes, a completely new refinery that came into existence after the initial period would still be able to seek an extension of the exemption. But the court could also construe extension in the temporal sense without requiring continuity. And in that case, it's certainly arguable that a new entrant would not be able to get an extension of the initial exemption because it didn't have one without there being any requirement that the extensions have been continuously enjoyed by others.

John G. Roberts 3:11

Well, which of those two readings of extension, I guess, each one of which you embrace, do you think is the right one?

Unknown 3:18

If we were forced to choose, Your Honor, we would acknowledge that reading extension in that temporal sense without continuity would enable the court to avoid having to decide whether this is one of those instances in which the same word has different meanings within the same statute. And so for that reason, perhaps, that might be a preferred reading. But even in that circumstance, our key point would be that even the temporal meaning of extension does not require continuity. Congress has used it in exactly the other way multiple times, and no dictionary says that the temporal meaning of extension requires continuity.

John G. Roberts 3:56

Well, it seems like you're sort of any port in a storm reading of this statute, and I'm not sure that's the strongest position.

Unknown 4:07

Well, then, Your Honor, we would be happy to rely on the other construction of extension as well, because extension is often used when there is some preexisting stat-separately authorized benefit, and it is being extended or made available to a different setting or time period or set of recipients.