AD Biogas To RNG Update
(BioCycle Magazine) The U.S. Environmental Protection Agency released the final Renewable Volume Obligations (RVOs) for the Renewable Fuel Standard (RFS) for 2020, 2021 and 2022 in early June.
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Biogas generated by anaerobic digestion qualifies as either a cellulosic biofuel (D3) or a non-cellulosic advanced biofuel (D5), depending on the digester inputs.
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“We understand why the final volumes are lower than anticipated, mostly because of actual year-to-date production, but we are concerned that the lower volumes undersell the true growth of the biogas industry,” says Patrick Serfass, executive director of the American Biogas Council (ABC). “There are several reasons to believe that the actual production coming soon will be significantly higher: new RNG projects have increased by 47% in the last year; on-farm projects have increased by 21%; and major companies have announced investments in new RNG projects totaling over $2 billion — twice the industry’s total investment in 2020. EPA’s final volumes only recognize a 13% growth from 2021-2022. We are hopeful that future volumes will anticipate the higher growth we see from American biogas fuel providers and developers.”
Serfass references an industry assessment released by Energy Vision in March 2022, which identified 230 operational projects in 2021 that were producing enough fuel to displace nearly 574 million gallons of diesel fuel. The assessment also identified 108 projects under construction last year, a portion of which have either started RNG production or will be producing RNG in 2022.
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The final rule also codified revisions to the definition of an agricultural digester to clarify that only animal manure, crop residues, and/or separated yard waste with an adjusted cellulosic content of at least 75% can be processed in such a digester in order to generate D3 RINs. (RINs are the currency of the RFS and are used by obligated parties as a compliance mechanism to meet the annual RVO mandate.) Food waste is categorized as a non-cellulosic fuel, i.e., it does not have a cellulosic content of at least 75%. “Food waste is essentially protein, sugar and fat,” notes Maureen Walsh, ABC’s federal policy director. “If an agricultural digester takes food waste as an input, it would have to go through a very rigorous and expensive testing process to prove it meets the adjusted cellulosic content of 75%.” The final rule includes a list of the feedstocks that agricultural digesters can process to have an adjusted cellulosic content of at least 75%. READ MORE