RNG Coalition testifies at EPA Renewable Fuel Volume Standard hearing

Members of the Coalition for Renewable Natural Gas (RNG Coalition), a group representing members of the renewable natural gas (RNG) industry headquartered in Sacramento, California, testified at the U.S. Environmental Protection Agency (EPA)'s public comment hearing for the 2018 Renewable Fuel Volume Standard proposed rule to advocate for RNG transportation fuel under the Renewable Fuel Standard (RFS) program. 

In recent years, RNG, which is produced from organic waste across the U.S. at landfills, wastewater treatment and agriculture facilities, has comprised a predominant majority of the cellulosic biofuel generated and registered under the RFS program, the RNG Coalition says.

"RNG has supplied 98 percent of the RFS’s cellulosic biofuel market since it received the D3 RIN designation in 2014," Ashley Patterson, vice president of government relations and public policy with Ameresco, a renewable energy systems provider in Framingham, Massachusetts, said during the meeting.

"RNG is America's cellulosic biofuel,” Luke Morrow, president of Midland Texas-based Morrow Renewables, a consultant for landfill gas plants, said during the comment period. "Our company has grown from about 25 employees in 2013 to over 100 today."

Nearly 40 of the 143 stakeholders preregistered to provide public testimony carried the RNG Coalition's message to EPA. RNG stakeholders said that EPA's cellulosic biofuel calculation methodology in the final rule account for both increased cellulosic biofuel generation from projects currently producing fuel, and the projected production from 24 additional RNG projects nearing completion of construction that are planned to begin generating RIN credits under the RFS program later this year and throughout 2018.

Kevin Dobson, vice president of business development with DTE Biomass, Detroit, told the EPA during the meeting that, "DTE Biomass is increasing production 18 percent in 2018 compared to 2017 due to plant upgrades and facility expansions currently underway at our existing projects."

"Across the country, RNG projects are under construction and anticipated to generate new cellulosic biofuel next year," said Patterson. "We are concerned that a 2018 Final RVO (renewable volume obligations), which does not take into account RNG projects under construction and increased generation from registered facilities has a strong risk of high inaccuracy, which can impact the RNG market, affecting jobs and slowing investments."

"I join the RNG Coalition in requesting that EPA also account for current market data, including data from construction in progress, investments made and pathway applications submitted and pending EPA approval," said Kathy MacBeth, director of sales and marketing with EcoEngineers, an auditing, compliance management and consulting firm in Des Moines, Iowa.

The RNG Coalition compiled data from RNG producers across the industry and presented a packet of 62 signed project affidavits to EPA at the hearing. 

"We look forward to further communication with EPA regarding the proposed rule via submission of our written comments from the RNG industry later this month," said David Cox, RNG Coalition director of operations.

The RNG Coalition was founded in 2011 and 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.