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Marcus Gillette, Director of Public Affairs

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Marcus@RNGCoalition.com

 

August 31, 2017

RNG Coalition Comments on EPA's Proposed 2018 Renewable Fuel Volumes

RNG industry advocates with Energy Vision, NGVAmerica, NWRA, and SWANA, that the final 2018 cellulosic biofuels volume account for fuel from 32 projects scheduled to come online by the end of 2018.

 

WASHINGTON, D.C. / / Today the Coalition for Renewable Natural Gas (RNG Coalition), Energy Vision, the National Waste and Recycling Association (NWRA), Natural Gas Vehicles for America (NGVAmerica), and the Solid Waste Association of North America (SWANA) submitted joint public comments to the U.S. Environmental Protection Agency (EPA)'s 2018 Renewable Fuel Volume Standard Proposed Rule to advocate for Renewable Natural Gas (RNG) transportation fuel under the Renewable Fuel Standard (RFS) program. 

"Consistent with the RNG industry's unified feedback to EPA at the 2018 RVO hearing on August 1st in Washington, D.C., EPA should take action to amend the proposed new methodology for projection of gaseous cellulosic biofuels in the 2018 RVO Draft Rule," stated Johannes Escudero, RNG Coalition CEO. 

RNG — produced from organic waste across the United States at landfills, wastewater treatment and agriculture facilities — qualifies as a cellulosic biofuel under the RFS program, which means RNG transportation fuel has lifecycle greenhouse gas emissions at least 60 percent less than a diesel baseline. In recent years, RNG has made up a predominant majority (over 95%) of the cellulosic biofuel generated under the RFS program. 

To reflect market reality, the RNG industry's comments ask that EPA set a final rule that adopts a more robust methodology, one that considers not just a limited set of historical data, but rather (1) all available RIN generation data, (2) volumes from projects that are pending registration with EPA, and (3) volumes from projects that are under construction or in substantial development and have submitted affidavits attesting to their anticipated 2018 production levels. 

"We have great appreciation for the substantial work EPA staff has undertaken to deliver the draft rule. However, the new method EPA proposes to use to count fuel availability is problematic," said David Cox, RNG Coalition Director of Operations and General Counsel. "RNG producers are on schedule to add 32 renewable natural gas facilities and 164.97 Million Gallons of fuel by the end of 2018 — additional fuel that goes unaccounted for in the proposed rule."

"Each RNG project provides 173 jobs and between $10 and $50 million in development investment," added Escudero. "This rule has great economic and energy security implications for the future of American fuel. It will determine whether we cede our energy security to foreign oil, or embrace the domestic production of clean renewable natural gas available today in communities across the country."

 

The Coalition for Renewable Natural Gas (RNG Coalition) - Founded in 2011, the RNG Coalition represents the renewable natural gas industry in North America, including companies that produce, or otherwise support production and distribution of biogas-derived renewable natural gas, which is a domestic, clean, low-carbon, and renewable source of power, heat and fuel that makes up the predominant share of Cellulosic Biofuel in North America.

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