RNG Coalition Executive Staff will testify at an EPA-hosted public hearing on June 25 in Kansas City, Kansas to comment on the RVOS proposed for 2015 and 2016.
Using a "neutral methodology" "aimed at accuracy," EPA adopted RNG Coalition submitted volume numbers, but only as part of its high end range scenario. For projects not yet in production, EPA adopted zero (0) as its low end range. The proposed RVO was set accounting for the twenty-fifth percentile (25%) of this range. For projects with a track record of production, EPA adopted a 12-month average of RIN generation as the low end range. The proposed RVO was set using the fiftieth percentile (50%) of this range.
The RNG Coalition will testify before EPA to address our expectations that the RNG industry will outproduce the proposed RVO for 2015 and 2016. We will urge an upward adjustment, including the need for EPA to consider: 1) new volumes and account for actual volume produced, 2) waiver credit reform and penalties for not engaging the market, and 3) other steps EPA should take to support the cellulosic biofuel market.
The RNG Coalition will file written comments with EPA by the July 27 deadline. For additional information, please contact RNG Coalition Executive Staff.