Electricity Renewable Identification Number Update

In 2019 the author wrote a manuscript for the Water Environment Federation Residuals and Biosolids Conference titled, “RIN and California LCFS Credit Revenue from Electric Vehicle Fueling with Biogas Fueled Combined Heat and Power.” The manuscript included a comprehensive analysis of the EPA-directed Renewable Fuel Standard (RFS) program, with specific emphasis on the electricity Renewable Identification Number (eRIN) pathway, and the California Low Carbon Fuel Standard directed by the California Air Resources Board (CARB). Since the 2019 paper was authored, CARB finalized rulemaking for biogas to electric vehicle charging credits. In December 2022, EPA submitted proposed changes to the RFS to activate the eRIN pathway, increase Renewable Volume Obligations (RVOs) for 2023-2025, and streamline the accounting protocol for utilities co-processing multiple feedstocks (e.g., wastewater residuals that qualify for D3 RINs and food waste and fats oils and grease (FOG) that qualify for D5 RINs). In a recent update in June 2023, EPA delayed the activation of the eRIN pathway due “a wide variety of comments on all aspects of the proposed eRIN program.” The intent of this manuscript is two-fold: 1) in anticipation of finalization of EPA RFS rulemaking regarding these matters, to chronicle those changes and summarize them for entities to assist them in understanding how to leverage the credits, and 2) through the process of developing the manuscript, advocate for biogas generators to achieve maximum credit value through a streamlined process. The manuscript will document the proposed changes, the comment-period process, and EPAs anticipated finalization of the rules in 2023 for implementation in January 2024. The outcomes of the rulemaking as well as the RVO updates will have critical implications for biogas generators looking to realize RIN credits for both renewable natural gas (RNG) and combined heat and power (CHP) production. See Figure 1 illustrating the biogas to energy options for wastewater utilities.