A Rightful Role in the RFS: The Electric Vehicle Market Is Predicted to Soar, and, Pending Overdue Action by the U.S. EPA, Biomass Power Producers Are Positioned to Help Meet Goals Set Forth in the Renewable Fuel Standard.

by Anna Simet (Biomass Magazine) ... The vast complexities of the RFS extend far beyond these components, but a much lesser-known provision is beginning to attract attention—the role of renewable electricity in the program, and it’s abilities to fuel electric vehicles (EVs). This provision is one that was embedded in the 2007 statute, but to date, has not been acted on, says Bob Cleaves, president of the Biomass Power Association.

"... The rule stated something very important that really dictated almost the entire cellulosic biofuel category since then—that nonliquid fuels, mainly renewable electricity from biomass or renewable natural gas (RNG), could be deemed as transportation fuels, provided it can be demonstrated they’re being used as such.”

The principals under that rule posed legal and practical challenges—for example, how the producer of the renewable electricity or RNG will demonstrate a specific volume was placed into a transmission system or commercial pipeline, that energy withdrawn from that pipeline or facility is matched with its ultimate use, and how to prevent fraud.

A few years later, EPA approved renewable electricity produced from biogas via landfills, wastewater treatment sludge and animal manure, as a cellulosic biofuel, and addressed some features of the rule, including how electricity will be tracked and how producers should document it. But as for solid fuel biomass, “they said in 2014 that it qualifies for renewable electricity under the RFS, but essentially, that they would leave it for another day,” Cleaves says. And as for progress since 2014, EPA has received many biogas electricity registration applications, but not one has been approved, a failure to act that Cleaves says is “part political and part legal, and also partly because of resource constraints within the agency.”

So how would biomass-based electricity affect the D3 market? Randy Lack, chief marketing officer at Element Markets, says there are still obstacles, but with the expected 481 million gallons of cellulosic biofuel to be produced in 2019, about 27 percent of that RVO pool could be made up from renewable biomass, based on the amount of qualifying power being generated today.

Further breaking the numbers down, about 2.3 million megawatt-hours of electricity currently go to fuel EVs, or about six percent of the generation of renewable biomass power being generated, Lack says.

The question now is how EV load development will be factored into RVO calculations, when this pathway moves ahead, Lack adds.

The only scenario supported by law and consistent with how RNG and other biofuels are managed, Cleaves says, is such that the producer of the power is awarded the RIN.

Alternatively, Cleaves says, a method BPA believes is simpler and ultimately fool proof, is that every producer that makes power that could be used as transportation fuel shares a split of the pot. “Everyone who produces power qualified under the program, would be registered and recorded in the EPA database, and on an annual basis, EPA would calculate how many EVs are on the road and how much power they consume, and therefore, how many RINs are potentially available from that pool of consumption. Then, they would take the amount generated and consumed, and give everyone a fractional or prorated RIN. It makes a lot of sense to do it that way, but either way, EPA has got to get off the dime and do it.”

For the impact earning RINs would have on the industry, Cleaves calls it “a game-changer, just like it was for RNG. Before the RFS, RNG was worth just about what the value of natural gas was,” he says. “A lot of new projects have come online and many are being developed, and it’s a really good thing for the bioeconomy.”

Cleaves says every Senate and House member who has a biomass or biogas plant in their state is aware of the eRIN issue, and that there is favorable language in the Senate House appropriations bills currently being worked on in conference. “We would like to strengthen those bills to send a very clear message to EPA that says this isn’t discretionary, it is mandated under the RFS, and it needs to be acted upon,” he says. READ MORE