One key reason for this is that domestic ethanol consumption this year has risen higher than previous estmates because gasoline consumption is at the highest its been in eight years.

The EIA's latest Short-Term Energy Outlook, which was released earlier this month, sets domestic gasoline consumption this year at 139.65 billion gallons. Assuming all gasoline contains 10 percent ethanol, that would put domestic ethanol consumption this year at 13.96 billion gallons. 

Indeed, the EPA's RIN data and ethanol exports, as reported by the RFA, point to a similar figure. According to the EPA, as of October, 12.28 billion RINs have been generated. On an annualized basis, 14.73 billion RINs will be generated this year. 

Meanwhile, the RFA reports that ethanol exports in the first nine months of the year totaled 624.9 million galllons. If we annualize this, 833.2 million gallons of ethanol will be exported this year. 

Using both of these figures, domestic ethanol consumption will likely be at 13.9 billion gallons, 3 percent higher than the 13.4 billion gallons originally proposed by the EPA in May.

As such, it is almost certain the EPA has to revise its target for 2015. Chances are strong it will also revise its target for 2016 upwards.

The EIA estimates gasoline consumption next year to be 139.8 billion gallons. Once again, assuming all gasoline contains 10 percent ethanol, that means next year's ethanol consumption will at least be 13.9 billion gallons. It should be noted that this figure does not include E85 or E15 sales. 

But with the installation of 5,000 flex fuel pumps in 1,400 stations next year, it is very likely that E15 and or E85 consumption will increase in 2016. This in turn brings the likely posssibility that the EPA's RFS target for 2016 will have to be higher than the 14 billion gallons it previously proposed.