The Coalition for Renewable Natural Gas (RNG Coalition) is continuing its efforts ensure Renewable Fuel Standard regulations do not undermine the ability of biogas-based fuels to help lower the carbon intensity of the U.S. transportation sector.&nbsp;The RNG Coalition on April 30 filed a supplemental petition with the U.S. EPA outlining continuing concerns with the agency’s Biogas Regulatory Reform Rule. An initial petition was filed by the group in September 2023.The RFS “set” rule, issued by the EPA in June 2023, included a wide variety of provisions related to the RFS program, including those focused on biogas regulatory reform. In an emailed statement, the RNG Coalition explains that those biogas provisions revised the process and requirements for generating renewable identification number (RINs) for biogas-derived fuels.&nbsp;“These regulatory provisions include&nbsp;substantial new requirements on previously unregulated parties, including&nbsp;registration, reporting,&nbsp;recordkeeping, and attest engagement requirements, as well as new, overly burdensome requirements on RNG producers,” the RNG Coalition continued in its statement.&nbsp;The organization in September 2023 filed an initial petition for reconsideration with the EPA expressing concern over many of the biogas regulatory reform provisions included in the “set” rule. The petition specifically urged the agency to reconsider the new regulations on biogas producers, including, but not limited to, the registration requirement and single use limitation; reconsider the testing and measurement provisions for biogas, renewable natural gas (RNG), and CNG/LNG; reconsider or provide further clarifying language regarding&nbsp; the generation of RINs for process heat, development and use of RING generation protocols&nbsp; for shared interconnections, and the addition of “leakage” as a reason for retirement of RINs; and reconsider the prohibition of off-site storage for RIN generation pending registration.The EPA in March <a href="https://www.epa.gov/fuels-registration-reporting-and-compliance-help/biogas-regulatory-reform-rule-alternative#:~:text=EPA%20also%20finalized%20a%20provision,accurate%20and%20precise%20as%20the">released guidance</a> on the alternative measurement protocol included in the biogas regulatory reform rule and in April <a href="https://biomassmagazine.com/articles/epa-reschedules-webinar-on-biogas-regulatory-reform-rule-provisions-of-rfs-set-rule">held a webinar</a> on the biogas regulatory reform rule provisions of the RFS.&nbsp;In its April 30 supplemental petition for reconsideration, the RNG Coalition indicates that the guidance issued by the EPA in March raises new grounds for objection. The supplemental petition also urges the EPA to administratively stay the biogas reforms or promptly initiate a rulemaking to defer implementation of the biogas reforms. “There are simply no grounds for the July 1, 2024 implementation date for new facilities, particularly where EPA has yet to provide sufficient guidance to these facilities and registrations must be submitted and approved prior to generation of [RINs] under the [RFS] program,” the group wrote in the document.&nbsp;“RNG Coalition has long noted our concerns with the lack of information EPA provided to support many aspects of the Biogas Reforms and have urged EPA to work with the industry to implement a workable program that does not undermine the incentives Congress sought to create,” the group said in its emailed statement. “We look forward&nbsp;to continuing our work with EPA&nbsp;with an interest in advancing the sustainable&nbsp;development, deployment, and utilization of renewable natural gas in the United States.”Full copies of the September 2023 and April 2024 petitions are both available on the EPA <a href="https://www.epa.gov/renewable-fuel-standard-program/petitions-reconsideration-or-rulemaking-under-renewable-fuel">website</a>.

2024-05-15 - RNG Coalition petitions EPA to improve, delay provisions of RFS biogas regulatory reform rule  (Biomass Magazine)

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The Coalition for Renewable Natural Gas (RNG Coalition) is continuing its efforts ensure Renewable Fuel Standard regulations do not undermine the ability of biogas-based fuels to help lower the carbon intensity of the U.S. transportation sector. 

RNG Coalition petitions EPA to improve, delay provisions of RFS biogas regulatory reform rule

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