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VI

E MAIL

Air and Radiation Docket

Docket No. EPA-HQ-OAR-2012-0401

Environmental Protection Agency

Mailcode: 6406J

1200 Pennsylvania Ave.NW.

Washington,

DC

20460.

Re: Docket ID No. EP A HQ OAR 2012 0401

July 12 2013

Notice o Proposed Rulemaking, 78

Fed Reg

36042

Regulation

o

Fuels and Fuel Additives: RFS Pathways II and Technical Amendments to the RFS2

Standards

Dear Madams and Sirs:

Vermont Energy Investment Corporation ( the Company ) appreciates this opportunity to comment on the U.S.

Environmental Protection Agency's ( EPA ) proposed rule published June 14, 2013, entitled Regulation o Fuels

and Fuel Additives: RFS Pathways II and Technical Amendments to the RFS2 Standards. The Company writes in

furtherance o the attached letter to EPA Acting Administrator Perciasepe from Vermont's delegation to the United

States Congress, dated June 27, 2013.

As

with the Vennont Congressional delegation, the Company applauds the proposed approval

o

a RIN generation

pathway for renewable electricity from landfill biogas as

a first step in bringing the Renewable Fuel Standard's

( RFS ) goals in line with new technology developments and recognizing the substantial benefits o electrified

transportation. The Company, however, encourages EPA to also include woody biomass and biogas from waste

digesters as feedstocks for renewable electricity in generating Advanced (D5) RINs and compressed/liquefied

natural gas in generating Cellulosic (D3) RINs. EPA already recognizes the equivalency

o

biogas from landfills

and waste digesters in its existing pathway for Advanced RIN generation for compressed/liquefied natural gas.

As

described below, restricting the renewable electricity pathway to only biogas from landfills is unnecessarily limiting

as

biogas from waste digesters used to produce renewable electricity and liquefied/compressed natural gas and

woody biomass used to produce renewable electricity also can achieve the necessary greenhouse gas ( GHG )

reductions to qualify for Advanced and Cellulosic RIN generation.

Along with the growth in vehicles sales, electric charging infrastructure is expanding as well. Enabling renewable

electricity from sources EPA has already recognized in other contexts

to

generate RINs when used

by

electric

vehicles will reinforce the private sector's investment in charging infrastructure and accelerate the adoption

o

electric transportation, which is essential to meeting national goals for reducing oil dependence and cutting GHG

emissions.

Business models that create a favorable return on investment are critical to the deployment

o

electric vehicle

charging infrastructure. Public and workplace charging are needed to expand electric vehicle deployment. By

enabling renewable electricity to generate RINs when used

by

electric vehicles, a new business model for electric

vehicle charging infrastructure providers can be established. This will lower the cost

o

electric vehicle charging and

enable a larger scale deployment

o

electric vehicle charging infrastructure powered by renewable electricity.

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Facilitating widespread availability

o

electric vehicle charging infrastructure supports the President's goal

o

l

million electric vehicles on the road by 2015.

Developing these pathways and enabling the generation o RINs from these sources enable wider deployment

o

electric vehicle charging infrastructure and promote integration

o

renewable power into transportation and into the

larger grid. When these sources

o

electricity are used

to

power our vehicles, the result

is

reduced reliance on

imported fossil fuel, stronger local and national economies and a cleaner enviromnent.

Specifically, the Company offers the following comments below.

I. Description

o

the Company s Renewable Electricity and Biogas Activities and its Potential

Role n Powering Vermont s Transportation Network

The Vermont Energy Investment Corporation (VEIC, www.veic.org) is dedicated to reducing the economic and

enviromnental costs

o

energy use, and to finding cost-effective ways to offset greenhouse gas emissions.

Founded in 1986, VEIC employs more than 300 professionals, with an annual budget o

85

million. t is

internationally recognized for advancing energy efficiency, conservation, and renewable energy plans and projects

in 35 states, 6 Canadian provinces, and 6 countries in Europe and Asia.

VEIC provides analysis, planning, evaluation, policy development, program design, management, and technical

support for projects in energy efficiency and renewable energy; transportation efficiency and mobility research; and

community energy initiatives, cost-effectiveness screening, and building codes and standards.

Currently, Vermont has 15 farm based waste digesters that process and collect the biogas emanating from waste

generated on the farms. Presently, all

o

these facilities combust the biogas that is collected on farm to produce

approximately 18,000 MWh

o

electricity. The electricity

is

primarily used to power homes and businesses in

Vermont. This electricity could be used

to

renewably power 5,000 electric vehicles in the State o Vermont

annually. Furthermore, the potential RIN generation revenue could be used

to

help finance other biogas collection

projects. Vermont has a potential

o

generating more electricity from waste digester biogas with the addition

o

a

new revenue source generated from RINs.

The State also has four facilities that process and combust woody biomass to produce nearly 340,000 MWh

o

electricity. This electricity could be used to renewably power approximately 95,000 electric vehicles in the State

o

Vermont annually.

II. Inclusion o a Pathway for Renewable Electricity from Waste Digester Biogas

In the proposed rnlemaking, EPA states that We

do

not at this point have sufficient information to evaluate the

lifecycle greenhouse gas emissions for production

o

renewable electricity ... from biogas from ... waste digesters.

Accordingly,

we

invite cmrunents providing information about these potential pathways. To this end, the Company

would like to assist EPA in gathering this data

so

that EPA may include electricity derived from waste digester

biogas in its finalized pathway for renewable electricity.

In a memorandum drafted by EPA in support

o

the pathway for renewable electricity from landfill biogas, EPA

stated:

The proposed lifecycle analysis

o

renewable electricity produced from landfill biogas focused on

emissions associated with production

o

the fuel. We did not consider any emissions from

production

o the feedstock because the biogas originates from municipal solid waste. Similarly,

there are no emissions associated with transportation

o

the renewable electricity (although losses

are accounted for), and no tailpipe emissions, so the only significant GHG emissions are derived

from fuel production.

1

1

U.S. Enviromnental Protection Agency, Memorandum to Air and Radiation Docket EPA-HQ-OAR-2012-0401,

Support for Classification

o

Biofuel Produced from Landfill Biogas as Cellulosic Biofuel and Summary o

Lifecycle Analysis Assumptions and Calculations for Biofuels Produced from Landfill Biogas (May 20, 2013).

V

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  s

with the renewable electricity from landfill biogas, waste digester biogas has no emissions from: (1) the

production

o

the feedstock (because the biogas originates from farm and food waste); (2) the transportation

o

the

renewable electricity; and (3) tailpipe emissions. EPA implicitly recognized the equivalency

o the two sources

when it provided a pathway for RIN generation for renewable compressed/liquefied natural gas from both landfill

gas and waste digester gas. s a result, the only potential difference in GHG emissions between renewable

electricity from digester biogas and landfill biogas should be the emissions derived from production o the fuel

i.e., combustion

o

the biogas and conversion into electricity). Any such differences should be very minor due to

the comparable processes used to convert landfill and waste digester biogas into electricity.

While the Company recognizes that there are some minor differences between the lifecycle emissions

o

converting

waste digester biogas and landfill biogas into electricity as well as the GHG baseline treatment between the two

sources, the Company urges EPA to conduct the very minor additional analysis that would be required to determine

that renewable electricity from digester biogas also meets the 50 percent and 60 percent GHG reductions necessary

to qualify for Advanced Biofuel and Cellulosic Biofuel RIN generation, respectively. The Company believes that

this should not

be

a difficult detennination to reach as EPA determined that the real GHG reductions resulting from

using renewable electricity from landfill biogas as a transportation fuel ranged between 96 percent (landfills that

flared biogas)

to

765 percent (landfills that vented biogas).

2

Such GHG reductions are far in excess

o

the

reductions necessary

to

qualify for RIN generation.

For the minor additional analysis that is required to make such a determination, the Company is available to meet

with EPA to help resolve any outstanding questions EPA may have so that it can finalize a pathway for renewable

electricity from waste digester biogas alongside its finalization

o

a pathway for renewable electricity from landfill

biogas.

To

that end, the Company suggests that the EPA utilize the data available and models

o

the Argonne

National Laboratory GREET model (Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation)

and the CA-GREET model, used for the California Low Carbon Fuel Standard, updated in 2012 with new vehicle

models, as a template for recognizing the multiple sources ofrenewable electricity.

s

a final point with respect to renewable electricity from waste digester biogas, as with landfill biogas, the

feedstock used to produce the biogas

is

primarily cellulosic in nature. Waste digesters typically use manure from

cows and other livestock as a primary feedstock, which

is

the result

o

diet

o

primarily cellulosic material (e.g., hay

and alfalfa).

s

a result, electricity from waste digester biogas should also qualify as Cellulosic Biofuel. The

Company is available to meet with EPA to discuss data that may aid EPA in reaching this determination.

Nonetheless, the Company recognizes that EPA may need additional time and resources to conduct an analysis

o

whether waste digester biogas meets the definition o a cellulosic biomass. Therefore,

i

an analysis

o

the cellulosic

content

o

waste digester biogas will take longer than it will take to finalize the renewable electricity pathway

generally, the Company encourages EPA to move forward with finalizing a pathway for renewable electricity from

waste digester biogas

as

an Advanced Biofuel alongside its finalization

o

renewable electricity from landfill biogas

as a Cellulosic Biofuel.

III Inclusion o a Pathway for Renewable Electricity from Woody Biomass

Additionally, the Company strongly encourages broadening the definition

o

renewable electricity and the

development o pathways for all renewable sources, including responsibly generated woody biomass. Woody

biomass is undoubtedly cellulosic in nature, and the question as to whether renewable electricity resulting from the

combustion

o

woody biomass qualifies as a Cellulosic, Advanced or Total Renewable Fuel is only dependent on the

associated GHG reductions.

s

with the pathway for renewable electricity from waste digester biogas, the Company encourages EPA to utilize

the data available and models

o

the Argonne National Laboratory GREET model (Greenhouse Gases, Regulated

Emissions, and Energy Use in Transportation) and the CA-GREET model, used for the California Low Carbon Fuel

Standard, updated in 2012 with new vehicle models, as a template for quantifying the GHG reductions associated

with using renewable electricity generated from woody biomass. Furthermore, the Company is available to meet

with EPA to discuss potentially available data that may aid in this determination.

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The Company recognizes that making such a pathway determination will take longer than it will take

to

finalize a

pathway for renewable electricity from landfill and waste digester biogas. Therefore, the Company encourages EPA

to

move forward with finalizing a pathway for renewable electricity from waste digester gas alongside its

finalization o a pathway for renewable electricity from landfill biogas in the event that the woody biomass pathway

requires significant analysis.

As mentioned above, the Company is available to meet and discuss this issue in detail with EPA s the Company

believes that inclusion

o

RIN generation pathways for renewable electricity woody biomass and biogas from waste

digesters alongside EPA s finalization o a pathway for renewable electricity from landfill biogas would

significantly further the deployment

o

electric vehicles in Vermont and nationally, and help the United States meet

the mandates

o

the RFS.

Respectfully submitted,

Karen Glitman

Director

o

Transportation Efficiency

Vermont Energy Investment Corporation