Regulatory Submissions

On February 10, APGA filed joint comments addressing concerns within an Environmental Protection Agency (EPA) proposed rule on Renewable Fuel Standard (RFS) Program: Standards for 2023-2025 and Other Changes. On this feedback, APGA partnered with other organizations aiming to achieve a robust renewable natural gas (RNG) market in the U.S., including the Coalition for Renewable Natural Gas (RNG Coalition), the National Waste and Recycling Association (NWRA), the Solid Waste Association of North America (SWANA), and Energy Vision (EV). APGA, along with these groups, represent the full value chain of biogas-derived fuels. 

The industry organizations urged the EPA consider the following in the final rule:  

1. To incentivize growth, finalize more robust cellulosic biofuel and advanced biofuel volumes for 2023-2025; 
2. Even when determining what is “achievable,” recognize the strong, potential growth of the RNG industry and not limit projections of renewable electricity from biogas based on ability to process registrations, and accounting for all potential feedstocks that may become available in this time frame;  
3. Incorporate a mechanism in the final rule that will allow for upward adjustments in the case of new fuels or underestimated projections; 
4. Implement a program for generation of Renewable Identification Numbers (RINs) for renewable electricity (eRINs) that allows RNG producers to be the RIN generator, reduces burdens on feedstock providers, and ensures flexibility in the market; 
5. Retain the current flexibility allowed for RIN generation and compliance with respect to RNG and delay the implementation of any biogas regulatory reforms until at least January 1, 2025; 
6. Continue to allow for storage while registration approvals are pending; and 
7. Support innovation and creation of additional markets for RNG, including, hydrogen, sustainable aviation fuel, and methanol. 

RNG meets all of the goals of Congress when it established the RFS program, and EPA should ensure a growing market for that fuel. APGA members can be a part, delivering RNG to help our country in reaching its clean energy goals using existing infrastructure and the current, trained workforce.