Letter urges Trump to direct EPA to complete RFS electric pathway

By Erin Voegele | August 24, 2018

On Aug. 17, the owners of nearly 60 anaerobic digestion (AD) projects sent a letter to President Trump asking him to tell the U.S. EPA to prioritize the development of an electric pathway under the Renewable Fuel Standard.

The letter cites efforts by members of Congress to encourage the EPA to take action on an electric pathway under the RFS, and notes that farmers from across the U.S. have testified at two EPA hearings in the past year on the issue and continue to engage the agency on the matter. “EPA has advised us that activating the electric pathway and helping farmers and rural communities is still not a priority, despite the goals you have set for your administration,” said the AD owners in the letter.

According to the letter, the EPA finalized regulations in 2014 that approve electricity approved from biogas as a cellulosic or advanced biofuel under the RFS, and established a corresponding RFS fuel pathway. “Unfortunately, though the pathway is in place and we are already producing electricity, we have not yet been able to participate because the agency refuses to approve applications to do so,” the AD owners said in the letter. “For four years, we have watched as other cellulosic and advanced biofuel producers benefit from the RFS program, while we have had to wait for EPA to enable us to do the same. The forgone revenues for our facilities are significant and have continued to grow, at the same time EPA has repeatedly acknowledged that significant shortages of cellulosic and advanced biofuels cause problematic market dynamics in the RFS program.”

The letter notes that approximately 250 dairy and livestock farms current generate electricity from AD. The USDA estimates another 9,000 farms could build AD facilities, given the right incentives. AD projects can also be developed at wastewater treatment plants and waste processing facilities.

Within the letter, the AD owners stress that AD facilities create a variety of economic and environmental benefits, but are largely dependent on revenue from electricity sales. In many cases, revue from electricity sales has plummeted. The RFS electric pathway, however, would provide many of these projects with an additional revenue stream.

“EPA action will mean we can finally receive credit for supplying RFS-approved biogas electricity to our nation’s electric vehicle fleet,” the letter states. “That is why we respectfully request your help to ensure that EPA acts on this matter this year. Please direct Acting Administrator Wheeler to follow through on your promise to America’s rural communities, make the Electric Pathway a priority, and get it done.”