Jim Lemon & Michael Lemon

March 17, 2016 | General

Commentary: Implementing The Electric RFS

Jim Lemon, Michael Lemon

Jim Lemon and Michael Lemon
BioCycle March/April 2016

Climate change is likely the greatest challenge we will face in our lifetimes. Following the historic Paris climate agreement last December (COP 21), the U.S. is leading a coalition of governments and private investors to identify solutions and invest billions to fight climate change. Steps to expand deployment of clean energy technologies like renewable power generation and electric vehicles (EVs) already are underway. We believe there is now a significant opportunity to further leverage those two technologies under the U.S. EPA’s Renewable Fuel Standard (“RFS”) program.
The RFS, or “ethanol mandate” as it’s commonly called, is a powerful tool intended to reduce U.S. carbon emissions and reliance on foreign oil by introducing increasing amounts of biofuels into the nation’s transportation fuel supply, particularly cellulosic biofuels. Critics have questioned its ability to achieve those goals, largely due to its heavy reliance on corn as a feedstock for ethanol production, and its failure to rapidly increase production of cellulosic biofuels, which have the lowest greenhouse gas (GHG) emissions. But nobody disputes that the RFS provides significant opportunities to spur development of new transportation fuels that can dramatically reduce carbon emissions.
Our company, Biogas Researchers, has been focused on identifying the most effective policy tool to increase utilization of anaerobic digester (AD)-produced biogas to power passenger vehicles. That tool became evident in July 2014 when EPA formally established a renewable electricity pathway under its RFS program. This pathway, or “electric RFS,” allows biogas-based electricity to be considered a cellulosic biofuel when used to power EVs. Using this pathway to combine biogas-based electricity with the incredible efficiency of EV drivetrains reduces GHGs by 96 percent when compared to burning gasoline in a conventional vehicle.

Boost To Biogas And EV Industries

The electric RFS has the potential to bring additional revenues to the biogas and EV industries, both relatively new in the U.S. and struggling to find a foothold. The struggle for AD biogas is highlighted in a recent Wall Street Journal article (“Energy Prices Steer Farmers Away From Manure Power”), which reported that low prices paid for biogas-based electricity are putting some agricultural digester projects on hold and others out of business. The article indicates that “construction of new U.S. farm digesters has slowed sharply over the past two years.” This calls into question whether efforts to significantly mitigate U.S. agricultural methane emissions, as outlined in the “Biogas Opportunities Roadmap” created by the U.S. Department of Agriculture, the Department of Energy and U.S. EPA, will come to fruition any time soon.
The difficulties faced by the agricultural digester industry are occurring at the same time that EV sales have plateaued, in large part due to low gasoline prices. Furthermore, while EVs have no tailpipe emissions, their potential to reduce GHG emissions depends not only on how many are on the road, but also on the fuels used to generate the electricity that powers them. EVs are a climate change solution only if they are paired with growth in renewable electricity. Otherwise they will have the unintended consequence of increasing fossil fuel consumption. A Washington Post article (“Electric Cars and the Coal that Powers Them”) describes the importance of matching growing EV adoption with increased renewable energy generation, and the consequences of a mismatch. The article cites how the Netherlands’ success in widespread EV adoption raised demand for electricity needed to power EVs. Mothballed coal-fired power plants had to be brought back online to fill the gap.
The electric RFS can help the U.S. achieve its climate change goals and give a much needed boost to the biogas and EV industries — all critical to reduce methane emissions and ground-level ozone, control nutrient runoff and address other negative impacts.

Urgent Action Required

In recent testimony before the Senate Environment and Public Works committee, Janet McCabe, EPA’s Acting Assistant Administrator for the Office of Air and Radiation, confirmed that Congress intended the RFS to “strongly incentivize growth in advanced fuels that achieve substantial greenhouse gas (GHG) reductions compared to the transportation fuels they replace.” Nonetheless, 20 months after it was created, the electric RFS remains unutilized, and EPA is still deliberating about how to implement it.
Last November, President Obama stated:“[i]f we want to prevent the worst effects of climate change before it’s too late, the time to act is now. Not later. Not someday. Right here, right now.” In that spirit, interested parties should request McCabe to implement the electric RFS in early 2016 in a way that: 1) Leverages the power of the marketplace to displace the maximum achievable amount of fossil-based fuels with renewable electricity; 2) Ensures that the assignment of renewable identification numbers (“RINs”) to renewable electricity appropriately accounts for its ability to power vehicles and displace fossil-based fuels, as it does for all other renewable fuels; and 3) Enables the maximum number  of anaerobic digesters to participate in and benefit from the RFS program. McCabe can be contacted at or (202) 564-7400.
Jim Lemon is president, and Michael Lemon is vice president of Biogas Researchers, Inc., a nonprofit in Washington, D.C., involved in research and educational activities to increase production and consumption of biogas. For more information contact:

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