As the Biden Administration builds its agenda on climate change and reducing greenhouse gas emissions, one issue under discussion is electric Renewable Identification Numbers, otherwise known as eRINs. Many policymakers view eRINs as a tool to use under the Renewable Fuel Standard (RFS) program to transition from liquid motor fuels to the electrification of the U.S. transportation system.
A little history of the RFS is needed to understand how the concept of eRINs emerged. In 2007, Congress passed the Energy Independence and Security Act (EISA), which expanded the RFS program to include any form of renewable fuel “produced from renewable biomass.” The legislation also directed the Environmental Protection Agency (EPA) to study the feasibility of issuing credits, called Renewable Identification Numbers (RINs), under the RFS to electric vehicles powered by electricity generated from renewable energy sources.
Ultimately, instead of completing the study, the EPA established a process for credit generation as part of its RFS rulemaking process in 2010. In the rule, the EPA included a provision to allow fuel producers, importers and end users to include electricity, natural gas and propane made from renewable biomass as a RIN-generating renewable fuel in the RFS. In 2014, EPA finalized pathways for compressed gas, liquefied gas and renewable electricity derived from biogas and used as a transportation fuel to qualify under the RFS. To date, the EPA has not approved any applications to generate eRINs or credits under the RFS program. The EPA has requested input on how to implement such a credit and who should receive the credit, which has been a main sticking point in implementing an eRINs system.
The House Special Committee on Climate Crisis included a recommendation in its staff report released last year on eRINs. The recommendation states that “unless or until Congress creates a federal low carbon fuel standard, Congress should direct EPA to complete any necessary rulemakings or other administrative steps necessary to allow the generation of eRINs for biogas-derived electricity used as a transportation fuel.” In addition, a group of nine bipartisan senators sent a letter led by Senator Susan Collins (R-ME) to encourage EPA to use its authority and allow eRINs.
Several environmental groups and the biogas industry support moving ahead with this program and believe it will encourage the transition to electric vehicles. Some in the oil and gas industry oppose moving ahead with eRINs due to the complexities in implementing such a program. Those that oppose the RINs system in general are reluctant to create another layer to the system with eRINs. All stakeholders, including the convenience and fuel retailing industry, will have to look closely at any proposal to see if an eRINs system is an opportunity or an obstacle.