Today, the American Biogas Council (ABC) submitted comments to the U.S. Environmental Protection Agency (EPA) proposed “Set Rule” regarding the Renewable Fuel Standard (RFS).
The proposed rule includes long-awaited guidance in a couple key areas plus multi-year fuel volumes for renewable electricity and renewable natural gas (RNG) made from biogas. “The ABC is pleased to see three years of renewable fuel volumes proposed for 2023-2025,” said Patrick Serfass, executive director, ABC. “Of the 2,300 biogas systems currently operational in the U.S., 2,000 of them produce uninterruptible renewable electricity and nearly 280 produce RNG.
This guidance from the EPA creates an opportunity for these projects as well as new ones to generate RFS credits (RINs) while also helping to decarbonize transportation and increase the volume of organic material that we recycle in the U.S. In the end, this will benefit the everyday American – those living and working on or near farms, food processors, and wastewater plants of all sizes.”
The ABC believes the RFS has helped to drive growth for the fast-growing U.S. biogas industry which has seen some sectors grow at over 40% annually. For that reason, we want to ensure the RFS continues to function well and urge the EPA to finalize the Set Rule, on time, by June 14. The ABC believes this is a major step forward in many ways, and supports many elements that will help accomplish the goals of the RFS, including: • EPA’s recognition that the overwhelming majority, over 95%, of cellulosic biofuel proposed to be produced from 2023-2025—719 million gallons for 2023, 1,419 million for 2024 and 2,131 million for 2025—will be derived from biogas; • Creation of a proposed regulatory framework for the renewable electricity pathway which will allow biogas electricity projects to thrive across the US, especially at small and medium sized farms, wastewater plants, and stand-alone food waste recycling plants; • Creation of a proposed regulatory framework to add food waste and D5 RINs to manure and wastewater biogas systems without devaluing the D3 RIN value these projects produce. This methodology should help remove one of the largest barriers to increasing food waste recycling in the US; and • EPA’s recognition of biogas as a cellulosic feedstock of the future. The proposed rule points to additional fuels that can be made with biogas as the feedstock, and we are very supportive of these additional uses for biogas.