American Biogas Council

Biogas Industry: Let's Get the RFS Electric Pathway Activated!
Ask your members of Congress to ensure that EPA implements the electric pathway under the Renewable Fuel Standard (RFS) program this year.

Three years ago the EPA published a final rule enabling valuable credits called renewable identification numbers ("RINs") to be generated for electricity produced with biogas and tracked to use in electric vehicles ("EVs"). Unfortunately, EPA has never approved any parties to participate in and benefit from the "eRIN" program. This delay costs the biogas industry tens of millions of dollars each year. Here is what you can do to help make activation of the eRIN program a high priority at EPA:

  1. Revise the illustrative pre-written letter as appropriate for your facility and/or situation.
  2. Mail or e-mail the letter to your congressional representative and your two senators.
  3. Email a copy of all three letters to info@americanbiogascouncil.org by July 15.
  4. Call your representative and senators to emphasize the importance of your request.

Sending us a copy of the letter is critical because our legislative team, working with ABC member BTR Energy, will follow-up with each congressional office behind you. We want to be able to reference your letter to ensure that they have received it and to remind them of the importance of getting EPA to implement the eRIN program in 2017.

Background and Other Information

What is the eRIN program?
The eRIN program is part of the EPA's Renewable Fuel Standard "RFS" program to increase the amount of biofuels used in America's transportation sector. If electricity produced with biogas can be matched with corresponding amounts of electricty consumed by EVs on a physically connected electric grid, valuable credits, or "eRINs," can be generated and sold in accordance with the RFS program. EPA published a final rule establishing the eRIN program on July 18, 2014, but it has never been implemented and EPA has never approved any parties to actually generate eRINs for electricity produced with biogas.

How is this different from RINs generated for biogas-based CNG?
Under the RFS program, each renewable fuel has a different "fuel pathway" that includes three critical components: (1) feedstock, (2) production process and (3) fuel type. Each combination of the three components is a separate fuel pathway that must be approved before RINs can be generated under that pathway. The main differences between the fuel pathway for bigoas-based CNG and that for biogas-based electricity -- both of which have been approved by EPA -- are the production process (e.g. pipeline injection vs. electricity generation) and fuel type (i.e. compressed or liquified gas vs. electricty).

Why has it taken EPA so long to implement the eRIN program?
For years, the eRIN program has apparently taken a back-seat to other programs and issues within the overall RFS program. But with the number of electric vehiles and buses growing rapidly, the size of the revenue losses to the bigoas industry is also growing, and those additional revenues are especially important to struggling agricultural facilities that generate electricity with biogas from manure. Therefore, the eRIN program neds to become a high priority at EPA now. Help us make it happen!

Where can I find more information on the eRIN program?
The regulatory provisions addressing the eRIN program can be found in the Code of Federal Regulations at 40 CFR ยง 80.1426 (f)(10)(i) and (11)(i). Additional information can be found at the links below.

June 2017 BioCycle Article on eRIN Pathway
January 2017 DOE Report on eRIN Pathway

Thank you for your action on this important initiative to create more incentives for new biogas projects.

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