WASHINGTON – MARCH 27, 2026 – American Biogas Council (ABC) Executive Director Patrick Serfass issued the following statement in response to EPA’s final Renewable Volume Obligations (RVOs) for 2026 and 2027:
“EPA’s final rule fails to represent real-world biogas growth, which will constrain markets. The action especially undercuts opportunities for livestock farmers, impeding one of the most reliable ways farmers can keep pace in a low-margin agriculture industry, and contribute to America’s energy dominance.
“In this set of fuel targets for 2026 and 2027, the agency diverged from longstanding methods and abandoned statutory guidelines when they estimated D3 RIN volumes on projected renewable natural gas (RNG) end-use constraints rather than what the U.S. biogas industry can produce – and even with this new approach, the agency has also significantly underestimated real-world demand. This approach looks to constrain domestic, renewable fuel production, a foundation of RFS goals, instead of supporting U.S. fuel industries which recycle organic residues, and more fully utilize American crops.
“Biogas systems on American farms convert waste into reliable, domestic energy and nutrient-rich soil amendments. When EPA undershoots the RNG market, it directly diminishes economic opportunities for anyone trying to turn these wastes into value. And in the way the RFS market works, the impact on U.S. farms may be the worst.
“The delay in issuing this rule has already slowed project development, raised financing costs, and stalled rural investment at a time when demand for domestic energy is rising. Adding to the disappointment, in this final rule, EPA failed to reallocate credits from waivers to the D3 RIN targets (which further diminishes the fuel targets) and has taken steps backwards on biogas to electricity eligibility.
“The data are clear: D3 RIN production has, on average, grown 20% every year since 2020, with 2024 representing record growth of 31%. By comparison, the final RVOs represent a mere 12% and 5% growth rate, for 2026 and 2027, respectively.
“The Set 3 rulemaking is around the corner, and it’s EPA’s opportunity to correct course. The agency should set D3 volumes that reflect actual production, support continued growth, and fully unlock biogas as a reliable source of American-made energy, fertilizer, and income for farmers, rural communities, and any sector with organic waste available to be recycled.”
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