New pathways proposed for RFS2
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June 13, 2013
New pathways proposed for RFS2

The addition of three new renewable fuel pathways highlights a set of amendments the EPA is proposing to the federal renewable fuel standard 2 (RFS2) program.  Also substantive are proposed modifications related to biogas, including revisions to the compressed natural gas (CNG)/liquefied natural gas (LNG) pathway.  According to the Agency, these fuels have the potential to add notable volumes of advanced biofuel, including cellulosic biofuel, to the existing renewable fuel volumes already being produced. 

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“Many of these changes are being proposed to facilitate the introduction of new renewable fuels under the RFS2 program and have come at the suggestion of industry stakeholders,” states the EPA.

Briefly, the following amendments are being proposed:

Pathways 

Under the RFS, a pathway is composed of the feedstock and the production technology used to generate the renewable fuel.  Under the action:

  • New pathways are proposed for renewable diesel, renewable naphtha, and renewable electricity (used in electric vehicles) produced from landfill biogas to generate cellulosic or advanced biofuel renewable identification numbers (RINs).
  • A new pathway is proposed to allow butanol made from cornstarch using a combination of advanced technologies to meet the 50 percent greenhouse gas (GHG) emissions reduction needed to qualify as an advanced renewable fuel. li>A change to the existing biogas pathway would specify that CNG or LNG is the fuel and biogas is the feedstock.

Misfueling

The proposal contains minor amendments to the misfueling mitigation regulations (MMRs) published in the July 25, 2011, FR.  These include corrections in the dimensions of the label and ensuring that the word “ATTENTION” is capitalized; clarification that E15 surveys need to sample for Reid vapor pressure (RVP) only during the high-ozone season or during any time RVP standards apply in any state implementation plan approved or promulgated under the Clean Air Act (CAA); a change to the time frame within which potential noncompliance detected by the survey must be reported to the Agency; and amended MMR definitions to address a concern about the rounding of test results for ethanol content violations.

Other elements

The proposal also:

  • Would amend the definition of “crop residue” to include corn kernel fiber.  This would allow corn kernel fiber to qualify for cellulosic ethanol and advanced biofuel RINs.
  • Requests comments on a lifecycle analysis of advanced butanol.  The analysis discusses the potential to allow for commingling of compliant products at the retail facility level as long as the environmental performance of the fuels would not be detrimental when compared to existing practices.  
  • Would allow a facility to use its nameplate capacity to establish its facility’s baseline volume for the purposes of registration.  Currently, the regulations allow a facility’s baseline volume to be established only by a limit stated in a permit or actual production records for at least 1 calendar year.   A facility would qualify for the nameplate provision provided it does not have a permit or there is no limit stated in the permit to establish permitted capacity, has not started operations or does not have at least 1 calendar year of production records, and does not claim exemption from the 20 percent GHG threshold (i.e., a 20 percent reduction in GHG emissions compared to GHG emissions from the production of gasoline or diesel sold or distributed as transportation fuel in 2005).
  • Would amend the ultra-low sulfur diesel (ULSD) survey provisions in a manner that will likely reduce the number of samples required.

Click here for EPA’s proposed amendments to the RFS2. 

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