(June 11, 2019) - NACWA and several member utilities joined the California Association of Sanitation Agencies (CASA) in a June 3 meeting with EPA to discuss the Renewable Fuel Standard (RFS) program. EPA attendees included Clint Woods, Deputy Assistant Administrator for the Office of Air and Radiation, and Jeff Lape, Deputy Director of the Office of Water’s Office of Science and Technology.
The RFS program offers incentives to produce renewable transportation fuels, including fuel produced from biosolids. Biosolids-derived fuel is classified as a cellulosic biofuel, which carries a D3 Renewable Identification Number (RIN). However, if food waste is added to anaerobic digesters to increase the production of biogas, all of the fuel produced will receive the D5 RIN for advanced biofuel. Since D3 RINs currently have a higher value than D5 RINs, utilities reduce their profits by receiving food waste at the digesters.
This situation conflicts with EPA’s Winning with Food Waste initiative and the Department of Energy and EPA joint challenge to expand renewable energy production at wastewater treatment plants.
This conflict was explained during the meeting with EPA, and CASA also explained how California legislation requires food waste to be diverted from landfills and why clean water utilities with anaerobic digesters are well-suited to accept food waste for biogas production. The utilities provided examples of their own biogas projects and how accepting food waste could greatly increase their biogas production, but these projects are hampered by the RFS disincentive to accept food waste.
The meeting resulted from a March 25 letter sent from CASA, NACWA, and two utilities to EPA Administrator Andrew Wheeler requesting his assistance in making changes to the Renewable Fuel Standard (RFS) program related to food waste and biogas. EPA expressed an interest in finding a solution, and NACWA will continue to work with CASA on this issue.
NACWA members that are considering or already using the RFS program are encouraged to contact Cynthia Finley, NACWA’s Director of Regulatory Affairs, for more information.