Renewable Electricity and the Renewable Fuel Standard – An Untapped Opportunity?
September 11, 2018 │ John Mosheim, P.E., CEM, Principal Water + Carbon Sustainability Engineer, GHG Engineering, LLC
The Renewable Fuel Standard (RFS) is a national policy created by Congress in 2005 that requires a certain volume of renewable fuel to be blended with petroleum-based fuel used for transportation in the U.S. The policy is intended to reduce greenhouse gas emissions, expand the renewable fuels sector, and shrink U.S. reliance on oil imports.
Fuel refiners or importers are obligated to meet annual RFS requirements and can do so through blending qualified renewable fuels directly into their products or through other means that generate credits known as Renewable Identification Numbers (RINs). Compliance pathways for RIN generation are the combination of feedstock, production processes, and resulting renewable fuel categories. The U.S. EPA (EPA) approves these pathways. Currently, electricity generated from the combustion of cellulosic biogas under the RFS is an approved pathway for RIN generation.
In July 2014 EPA approved this pathway for RIN generation from electricity derived from biogas feedstock from a variety of anaerobic digesters. In other words, under the RFS, renewable electricity produced from cellulosic biogas is considered a transportation fuel when used in electric vehicles.
Despite EPA’s acknowledgment of electric RINs (eRINs) over four years ago, eRIN regulatory and administrative details have not been finalized by the Federal Government. Examples of unresolved items include “completion of the full administrative rulemaking process,” clarification of eRIN credit ownership, and issuance of guidance documents as others have noted. Therefore, the potential sustainability and economic benefits from marketing eRINs remain untapped. As an illustration, EPA reported that the industry generated 250.6 million Cellulosic Biofuel RINs in 2017 and no eRINs. The average reported value of each Cellulosic Biofuel RIN in 2017 was in the range of approximately $2.
On the other hand, the growing commitment by many states to both reduce greenhouse emissions and increase the number of electric vehicles in state-wide fleets could be the driver that mobilizes all stakeholders to work together and make eRINs an active part of the RFS.
While the use of eRINs under the RFS remains stalled, the potential economic and emissions-reducing benefits of this pathway remain unrealized.
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Note: The above information is not to be considered or construed as any kind of direct or indirect advice or recommendation regarding any aspect of the RFS or related federal, state, or local program, either from the technical, regulatory, or policy perspective(s). The views expressed in this blog are those of the author alone. An effort has been made to present the information as accurately as possible; however, should any discrepancy be found please contact the author so that the appropriate revisions can be made. The author also wants to note that the RFS is a complex program and the above summary has been simplified for the purpose of ease of communication.
John Mosheim, P.E., CEM is Principal Water + Carbon Sustainability Engineer at GHG Engineering, LLC, a sustainability engineering consultancy located in Rockville, Maryland. John can be reached at email@example.com or via telephone at 443-370-5956.
 Renewable fuel producers generate RINs. One (1) RIN has the equivalent energy of one gallon of denatured ethanol or 77,000 BTUs (LHV), 22.6 kW-hr of electricity represent one (1) RIN.
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