Regulatory Submissions

On December 1, APGA joined with others in sending a letter to the Environmental Protection Agency (EPA) regarding biogas regulatory reforms, an effort being led by the Renewable Natural Gas (RNG) Coalition.

APGA members are considering using RNG in their systems, so they are directly and indirectly affected by these biogas regulatory reforms. They require substantial changes to how the RNG industry has operated under the Renewable Fuel Standard (RFS). As the letter details, the greatest concern lies in EPA’s mandate for continuous measurement, using specific in-line gas chromatographs (GCs) and orifice, vortex, or thermal mass (capillary) flow meters. These prescriptive requirements raise serious concerns. The letter emphasizes the diverse factors that influence the choice of measurement devices and argues against the one-size-fits-all approach. EPA needs to explain why specific devices were chosen.

After the reforms were finalized, the RNG Coalition submitted a Petition for Reconsideration to address these onerous requirements. APGA and others, through this letter, are urging EPA to grant that Petition for Reconsideration and Request for Stay, to allow for further discussions with the industry.

APGA will continue to work on this issue and will inform members of any progress on these regulations.