August 20, 2018
RNG Industry’s Joint Comments to U.S. EPA’s 2019 Biofuel Rule Applaud Proposed Increases in Cellulosic & Advanced Biofuels, Urge Stability
Washington, D.C. – The Coalition for Renewable Natural Gas (RNG Coalition), Energy Vision, National Waste and Recycling Association (NWRA), Natural Gas Vehicles for America (NGVAmerica), and Solid Waste Association of North America (SWANA) submitted joint comments on August 17 to the U.S. Environmental Protection Agency (EPA) on proposed 2019 Renewable Fuel Volume Obligations (RVO) under the federal Renewable Fuel Standard (RFS). The organizations collectively represent the full value chain of biogas-derived cellulosic biofuel under the RFS.
“The Renewable Natural Gas (RNG) industry is leading the way in the delivery of cellulosic biofuel in the United States, making up over 95 percent of our nation’s cellulosic biofuel production and generation of D3 Renewable Identification Numbers under the RFS,” said RNG Coalition CEO Johannes Escudero. “Our comments are supportive of EPA’s proposal to increase the 2019 minimum applicable volume for both cellulosic and advanced biofuels from 2018 to reflect the continued growth and investments being made in the RNG industry.”
The RFS program has successfully promoted production of renewable natural gas. Since 2011, the RNG industry has developed over 45 new facilities currently producing cellulosic biofuel, and there are currently more than 50 additional projects under construction or development. The industry’s cellulosic biofuel production has increased from approximately 33 million gallons in 2014 to over 240 million gallons in 2017.
“RNG investors and developers require certainty and stability to build new production facilities to expand production,” said David Biderman, SWANA Executive Director and CEO. “We appreciate the signal of stability from EPA in its use of consistency to project available cellulosic biofuel for 2019 in the proposal.”
The comments urge EPA to continue RFS implementation using a predictable methodology for projecting available cellulosic biofuel by providing a consistent formula and consistent data to the RNG industry by which investment decisions can be made.
“We look forward to collectively working with the administration in future years to ensure that the methodology used to set cellulosic biofuel requirements accurately reflects the RNG industry’s investments and that the program is administered in a way that allows for these gallons to be used in the marketplace,” said David Cox, RNG Coalition General Counsel and signatory on the comments.
About the Coalition for Renewable Natural Gas
The RNG Coalition is the trade association representing over 135 companies and organizations dedicated to the advancement of RNG, including as an ultra-clean, domestically produced, renewable fuel in North America. The RNG industry captures and converts methane (raw biogas) emitted by and captured from organic waste streams such as those from landfills, wastewater treatment facilities, livestock and agricultural digesters, and commercial food waste facilities, and converts the biogas into RNG. RNG is fully fungible with conventional natural gas, and is used as a direct substitute for most commercial, industrial and residential natural gas applications.
About Energy Vision
Energy Vision (EV) is a not-for-profit think tank whose mission is to research, analyze and promote the technologies and strategies – viable today – required to transition toward a sustainable energy and transportation future. Since 2010, EV has been the leading independent environmental organization looking at the production and use of renewable natural gas (RNG) as a transportation fuel.
About the National Waste and Recycling Association
The NWRA is a not-for-profit trade association representing private solid waste and recycling collection, processing, and management companies that operate in all fifty states.
About Natural Gas Vehicles for America
NGVAmerica is a non-profit trade association dedicated to the development of a growing, profitable, and sustainable market for vehicles and carriers powered by natural gas or biomethane. Its member companies produce, distribute, and market natural gas and biomethane, manufacture and service natural gas vehicles, engines, and equipment, and operate fleets powered by clean-burning gaseous fuels across North America.
About the Solid Waste Association of North America
SWANA is an organization of more than 10,000 public and private sector professionals committed to advancing from solid waste management to resource management through their shared emphasis on education, advocacy and research. For more than 50 years, SWANA has been the leading association in the solid waste management field. SWANA serves industry professionals through technical conferences, certifications, publications, and a large offering of technical training courses.
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