Clean Water Current

NACWA Supports Changes to Renewable Fuel Standard to Incentivize Co-Digestion of Food Waste

Feb 22, 2023

NACWA submitted comments February 10 on EPA’s proposed changes to the Renewable Fuel Standard (RFS) regulations, supporting changes that would help clean water utilities benefit from the program.  The RFS provides incentives to produce renewable transportation fuels, including the biogas produced by anaerobic digestion of biosolids.    

The current RFS classification of biofuels creates a disincentive for utilities to consider co-digestion of biosolids and food waste. The California Association of Sanitation Agencies (CASA) and NACWA have advocated for several years for EPA to consider alternative methods for classifying biofuel feedstocks to better incentivize the beneficial management of food waste through co-digestion.  The proposed changes to the RFS would allow utilities to determine the amount of biogas produced from biosolids, and assign this a cellulosic biofuel, which carries a more valuable D3 Renewable Identification Number (RIN) in the RFS program.  The amount of biogas produced by co-digestion of food waste will then receive the less valuable D5 RIN for advanced biofuel.  

The proposed rule changes would also allow renewable electricity to be considered a transportation biofuel and qualify for RINs.  Electricity produced at wastewater treatment utilities would qualify for these “eRINs.” NACWA asked EPA to allow the electricity produced at wastewater utilities that is used on-site to qualify for eRINs, since this practice reduces the electricity utilities use that is generated from other sources.   

NACWA will notify members of the final outcome of the proposed changes to the RFS.  Members who are using or planning to use the RFS for the biofuels produced at their facilities are asked to contact Cynthia Finley, NACWA’s Director, Regulatory Affairs, so the Association can learn more about how its members are utilizing the RFS incentives.   

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