RNG industry asks EPA to increase 2020 RVO for cellulosic biofuel

By Erin Voegele | August 08, 2019

More than 40 members of the renewable natural gas (RNG) industry sent a letter to U.S. EPA Administrator Andrew Wheeler Aug. 7 urging the agency to set the 2020 renewable volume obligation (RVO) for cellulosic biofuel at a minimum of 650 million gallons to account for all the RNG that will be produced and available next year.

The letter notes that the RNG industry has experienced significant growth since 2014, and now constitutes more than 96 percent of the fuel used to meet the cellulosic biofuel requirement of the RFS. The EPA has proposed to set the 2020 RVO for cellulosic biofuel at 540 million gallons, up slightly from 420 million gallons in 2019. A public comment period on the proposed 2020 RVOs is open through Aug. 30.

Within the letter, the members of the RNG industry asks the EPA to consider three main components when projecting available RNG volumes. The first is historical methodology. The letter notes that for 2018 and 2019 the EPA utilized an “industry-wide” approach and a historical growth rate methodology to project the RNG volumes based on the most recent 12 months for which data is available. However, the industry exceeded the growth rates projected by the agency. Based on a review of upcoming projects, the RNG industry members said believe a growth rate of 41.5 percent is an appropriating starting point for the EPA’s “industry-wide” approach.

Second, the letter urges the EPA to account for small refinery exemptions (SREs). For the 2017 compliance year, SRE approvals reduced RVOs by 9.4 percent. “Barring a change in EPA policy on granting SREs, the RNG component of the cellulosic biofuel requirement for 2020 should be adjusted upward by 9.4 percent to account for the impact of SREs,” the industry members said in the letter.

Third, the letter also indicates the EPA should increase the 2020 RVO for cellulosic biofuel to account for production not accounted for in its historical methodology. The letter stresses EPA is required to fully account for available production, including projects currently under construction and expected to come on-line within the time frame that will impact the 2020 RVO. “These additional projects will in all likelihood push actual RNG production in 2020 above the levels contemplated with an updated 41.5 percent growth rate, and these additional volumes should be incorporated in the cellulosic biofuel standard,” the RNG industry members wrote.

The letter follows testimony offered by RNG stakeholders during a hearing held on the 2020 RFS proposal July 31.  

A full copy of the letter can be downloaded from the Coalition for Renewable Natural Gas website.