Renewable Electricity and the US EPA Renewable Fuel Standard (RFS) – An Untapped Opportunity?

The RFS was created by Congress in 2005 with the objective of reducing greenhouse gas emissions, expanding the renewable fuels sector, and reducing the U.S. reliance on oil imports. Currently, electricity generated from the combustion of cellulosic biogas under the RFS is an approved pathway for Renewable Identification Number (RIN) generation (*).

The main focus of the RFS is transportation sector fuels, specifically diesel and gasoline. A pathway is the combination of feedstock, production processes, and resulting renewable fuel categories. The U.S. EPA (EPA) approves these pathways.  In July 2014 EPA approved a 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.

However, as of mid-2018, 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 benefits from marketing eRINs remain untapped.  As an illustration, EPA reported that 250.6 million Cellulosic Biofuel RINs (No eRINs) were generated in 2017. 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 the state’s fleets could be the driver that mobilizes all stakeholders to work together and make eRINs an active part of the RFS.

John Mosheim, P.E., CEM is Principal Water + Carbon Sustainability Engineer at GHG Engineering, LLC, a sustainability engineering consultancy located Rockville, Maryland. 

For additional details see:  and

Image: US DOE

(*) 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.

The above information is not to be considered as any direct or indirect advise or recommendation regarding the RFS or related federal, state, or local programs, either from the technical, regulatory, or policy perspective(s). The views expressed in this document are those of the author alone. An effort has been made to present 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.

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