That's the description from the National Corn Gowers Association of a bankrupt refiner's RIN plan. NCGA President Kevin Skunnes tells The Big Show poor financial decisions and management caused a Pennsylvania refinery to file for bankruptcy protection, not the Renewable Fuel Standard. NCGA this week submitted formal comments to the U.S. Department of Justice on the proposed settlement agreement between Philadelphia Energy Solutions, or PES, and the Environmental Protection Agency. The settlement stems from the outstanding RFS compliance obligations the refiner has included in its Chapter 11 bankruptcy filing. NCGA claims the settlement would undermine the RFS. The association’s comments state the proposed settlement would allow the refiner “to walk away” from more than half of its outstanding RFS obligations and allow its parent companies to avoid liability. Skunes adds the proposal “would have negative policy implications for the RFS and future compliance with the Clean Air Act,” as the settlement does not hold all parties liable for violations of the Clean Air Act. The bankruptcy court will decide on the settlement agreement on April 4th.