Why is this good for the environment?

According to a study by the US Environmental Protection Agency (EPA), using waste biomass to make electricity in electric vehicles represents a 96% reduction in greenhouse gas (GHG) emissions compared to conventional vehicles using gasoline and diesel. For the same gallon of gasoline, EVs travel three times the distance. On top of that, the fuel is from a non-fossil source that would otherwise emit harmful methane gas, which is 32 times more potent than carbon dioxide and a major contributor to climate change. As more Americans choose electric vehicles, being able to match the use of EVs with reliable and renewable sources of power that reduce methane emissions is essential for de-carbonizing the transportation sector.

How significant are these benefits?

Again using EPA data, generating electricity from wastes makes a dramatic contribution to the reduction of GHG emissions. For example, matching biogas-derived electricity with EVs is equivalent to removing 21 million vehicles from the road, or avoiding all of the carbon from 550,000 railcars of coal annually. To put in this context of other technologies like solar, using biogas for transportation avoids 100 million metric tons of carbon dioxide annually compared with an estimated 73 million tons of carbon avoided by all of the Nation’s solar panels in use today.

How would this work?

Electricity is already included in the Renewable Fuel Standard (RFS). The EPA simply needs to implement the electricity portion of the program. To do this, the agency would need to calculate how much electricity is available to qualify for the program, and then to process the applications that are currently pending. We estimate that there are 200-300 million gasoline gallon equivalents available for inclusion in the RFS for 2019. This number will grow as the transportation sector becomes more electrified. In fact, if EPA correctly applies the “equivalence” of biomass electricity by taking into consideration the efficiency of electric drivetrains, we estimate that biomass electricity used for transportation could well exceed existing volumes in the 2019 target. By law, electricity would mostly fall into the cellulosic, or what is called the “D3 category”, which has a target of 418 million gallons for 2019.

How does the RFS work? Does the program expire?

Refiners are considered obligated parties. They are “obligated” to source renewable biomass, either by blending it with their non-biomass fuel or by buying credits known as “RINs” (which stands for Renewable Identification Numbers). EPA sets the market each year with the Renewable Volume Obligation (RVO), which determines how many gallons (or in the case of renewable gas or biomass-derived electricity, “gasoline gallon equivalents”) of each type of qualifying fuel will be available the following year for obligated parties to blend or purchase credits for.

What is the legal basis for including electricity in the RFS?

Electricity was included as an accepted transportation fuel in the Renewable Fuel Standard II, which was signed by President George W. Bush on December 19, 2007. Since then, the EPA has included electricity in several of its own rulemakings, including the 2010 and 2014 REGS Rules – but has so far failed to implement the electricity part of the program.

What does this mean for cleaner transportation?

The Renewable Fuel Standard requires the EPA to set a target each year for the following year’s renewable fuels volumes in several different categories. Obligated parties are required to purchase credits based on these targets, known as the Renewable Volume Obligation (RVO).

These targets are determined using gallons of fuel as the measurement. Power is produced, on the other hand, using a kilowatt hour increment. To “translate” fuels from gallons to kilowatt hours, the EPA has developed a model that takes into account average miles driven by EVs and comparing, for that distance, the liquid fuel that would be used to the amount of power that would be needed to charge a car.

The EPA has recognized that electric engines are approximately three times more efficient than traditional internal combustion engines (79 FR 42142)  – in other words, a gallon of gasoline would get you a third of the distance as the comparable kilowatt hour charge.  This should be taken into account when determining the value of electric RINs.

What types of biomass qualify?

The RFS defined several types of feedstocks that would qualify under the RFS. In some cases, the same feedstocks that are used to make liquid or gas fuels can ALSO be used to make electricity. Some of the qualifying electricity feedstocks include: biogas (manure that is used in an anaerobic digester on a farm; waste at a wastewater treatment plant or a landfill), biomass (tops and limbs of trees that are harvested for other purposes; rice and oat hulls; nut shells; clean urban wood waste), and waste-to-energy (the biogenic portion of garbage that is left over after recyclable materials are removed).

Why hasn’t this been done?

That’s a good question, and we don’t know the answer. Congress approved this in 2007, and the EPA has demonstrated agreement in its rulemakings. The EPA should implement the program without delay.

Is a rulemaking required?

Three separate rulemakings have been done already that would enable the EPA to implement the program – the 2010 and 2014 REGS Rules, which have been finalized, and the 2016 REGS Rule, which has not. Implementing the program needs no further rulemakings.

How do these technologies work?

Biomass, biogas and waste-to-energy rely on materials that are already part of the carbon cycle rather than being extracted from below the earth’s surface. They harness energy from materials that have little to no other value and would otherwise decompose, emitting a harmful methane gas. In using them to power transportation, you get double the benefit – low carbon transportation fuel plus the reduction of methane emissions. 

Why not solar, wind and other renewables?

Congress intended the RFS to incentivize the replacement of fossil-based transportation fuels with organic fuels. The program is specific to biomass and does not include any other types of fuel. Other fuels that do qualify include ethanol, renewable natural gas (RNG), compressed natural gas (CNG), liquified natural gas (LNG), and renewable hydrogen. That said, other renewables play an important role in complementing biomass, which provides reliable, base-load power.