RNG Coalition Comments on EPA's Request for Further Comment on 2018 RFS Volumes
On October 19, RNG Coalition staff submitted comments in response to EPA's request for further comment on proposed changes to the 2018 Renewable Volume Obligations (RVO).
While EPA's late September Notice of Data Availability does not include proposed reductions in cellulosic biofuel, it indicated that EPA is considering reductions in the RFS obligations for the advanced biofuel, biomass-based diesel (BBD) and total renewable categories, and exploring further use of EPA's waiver authority.
The RNG Coalition's comments:
- Call on EPA to fulfill Congressional intent and the purposes for the RFS by considering increases to 2018 RVO volumes;
- Reiterate the shortcomings of EPA's proposed use of only historical data in its new methodology for projecting cellulosic biofuel volumes; and
- Explain the RNG Coalition's opposition to EPA's attempts to rewrite its waiver authority.
Read the RNG Coalition's submitted comments HERE.