MEMORANDUM

TO: Air and Radiation Docket EPA-HQ-OAR-2015-0111

FROM: Dallas Burkholder, Office of Transportation and Air Quality, US EPA

DATE: November 2015

SUBJECT: November 2015 Assessment of Cellulosic Biofuel Production from Biogas (2015-

2016)

Projecting Cellulosic Biofuel Production from Biogas

As discussed in Section IV of the preamble of the final rule to establish volume standards for 

2014-2016, EPA projected the generation of cellulosic biofuel RINs for compressed and liquified 

natural gas (CNG/LNG) derived from biogas for 2015 and 2016 using information from EMTS 

and projections submitted to EPA from the Coalition for Renewable Natural Gas (CRNG).

2015 Projection 

The first step of the methodology we used to project the number of cellulosic biofuel RINs 

generated for CNG/LNG derived from biogas was to review the RIN generation history for these 

fuels over the most recent 12 months for which information was available (October 2014 –

September 2015). Unlike in the proposed rule, a pathway for generating cellulosic biofuel RINs 

for CNG/LNG derived from biogas has been in place throughout this period, so only cellulosic 

RINs need to be considered. The monthly production history for RINs generated for CNG/LNG 

derived from biogas, and those retired for reasons other than demonstration of compliance with 

the annual standards, is shown in Table 1 below.
Table 1

Cellulosic Biofuel (D3) RINs Generated for CNG/LNG Derived from Biogas

Month Number of Cellulosic RINs 

Generated for CNG/LNG

October 2014 6,617,128

November 2014 6,152,005

December 2014 8,773,943

January 2015 3,994,216

February 2015 7,865,221

March 2015 7,716,541

April 2015 7,542,563

May 2015 9,227,030

June 2015 12,223,962

July 2015 12,651,824

August 2015 13,478,314

September 2015 12,316,744

Total RINs Generated 108,559,491

RINs Retired for 

Reasons Other than 

Demonstration of 

Annual Compliance1

1,122,021

Total RINs Available 107,437,470

Since we have actual data on the generation and retirement of cellulosic biofuel RINs produced 

for CNG/LNG derived from biogas for the first nine months of 2015, we only need a projection 

for the remaining three months of the year (October 2015 – December 2015). Based on available 

EMTS information we have determined that 87,016,415 cellulosic biofuel RINs were generated 

for CNG/LNG in the first nine months of 2015 and remain available for compliance purposes. 

For the last 3 months of 2015, we have calculated low and high ends of a range of potential 

production volumes. We project likely production volumes using a production volume at the 

75th percentile of the range for all facilities that have previously generated cellulosic biofuel 

RINs for CNG/LNG derived from biogas, and production volume at the 50th percentile of the 

range for facilities that have not yet generated cellulosic biofuel RINs.

In our proposed rule we projected volumes from these facilities at the 25th and 50th percentile of 

the projected production ranges respectively, consistent with the way we projected likely 

production from liquid cellulosic biofuel producers. We received comments that our 

methodology under-estimated the potential for the generation of cellulosic RINs from biogas, 

with some commenters claiming that the mature state of the technology required to produce 

and/or collect biogas and clean it to pipeline quality justified a using a higher percentile to 

projected production from these facilities. In our proposed rule EPA noted the differences in the 

status of the technologies used to produce liquid cellulosic biofuels and cellulosic biofuel from 

biogas. We nevertheless proposed to use the same percentiles for both liquid cellulosic biofuels 

 

1 Data is from EMTS. No RINs will need to be retired due to the export of RIN generating CNG/LNG since 

verification of the fuel’s use as transportation fuel in the United States is a condition of RIN generation. 
and cellulosic biofuel from biogas due to uncertainties related to the ability of the biogas 

production facilities to demonstrate the use of the biogas as transportation fuel and a lack of RIN 

generation data to compare to previous projections on the part of many of the biogas facilities. 

After reviewing the fuel production and RIN generation history of these facilities, and with these 

comments in mind, EPA has decided to use higher percentile values to project likely production 

from cellulosic biogas producers as compared to liquid cellulosic biofuel producers.

The low end of the projected production range for CNG/LNG produced from biogas is equal to 

the number of RINs generated for CNG/LNG produced from biogas in the most recent 12 

months in which data is available, multiplied by a scaling factor of 0.25 (the portion of the year 

for which we are projecting volumes). This calculation results in a low end of the projected 

range for CNG/LNG produced from biogas in the last three months 2015 of 27 million gallons.2 

In deriving the low end of the projected production range for the last 3 months of 2015 we 

assume the production rate of RINs generated from CNG/LNG does not increase. While we are 

aware of several facilities that have registered with EPA and have not yet begun producing RINs, 

as well as the intention of several existing facilities to increase production through the end of 

2015 we do not believe it is appropriate to consider these additional volumes in the low end of 

the projected production range. The production of biogas from landfills and digesters, as well as 

the volume of CNG/LNG that registered facilities can demonstrate was used as transportation 

fuel in the United States, are both variable and may fluctuate over time. Any growth in RIN 

generation from a new or existing facility may be off-set by a decrease in production from 

another facility. Additionally, producers of CNG/LNG may decide to sell the CNG/LNG they 

produce to non-RIN generating markets, such as electricity generation. This approach to 

projecting the low end of the range is consistent with the approach taken for cellulosic biofuels 

other than CNG/LNG.

To calculate the high end of the projected production range for CNG/LNG derived from biogas 

in the last three months of 2015 we primarily relied on cellulosic biofuel RIN generation 

projections provided by CRNG when available, and facility capacity and RIN production history 

when other projections were not available. The high end of the range is designed to represent the 

number of cellulosic biofuel RINs that could be generated for CNG/LNG if there are no 

unexpected interruptions in the production of CNG/LNG from biogas or the verification of the 

use of this CNG/LNG as transportation fuel within the United States. We reviewed the data 

available in EMTS for all facilities registered to produce cellulosic biogas RINs for CNG/LNG 

derived from biogas. Each of the facilities, along with the cellulosic biofuel production in 2014

and 2015 (through September 30, 2015), total permitted capacity and total actual peak capacity 

are shown in Table 2 below. At the time of the assessment eight additional facilities had 

requested registration as producers of cellulosic biofuel from CNG/LNG derived from biogas but 

their registration applications have not yet been processed. These facilities are also listed in the 

Table 2. 

 

2 For the purposes of our projections all volumes are rounded to the nearest million gallons
Table 2

Registered Producers of Cellulosic Biofuel RINs for CNG/LNG Derived from Biogas

Company Name Facility Name

2014 Production 

(Cellulosic)

2015 Production 

(Jan. - Sept.)

Permitted 

Capacity Actual Peak

HIGH MOUNTAIN FUELS, LLC Altamont Liquefied Biogas Plant

Dallas Clean Energy McCommas Bluff Dallas Clean Energy McCommas Bluff

Canton Renewables, LLC Canton Renewables, LLC

quasar energy group, llc Central Ohio BioEnergy, LLC

AMP Americas LLC Renewable Dairy Fuels

quasar energy group, llc Zanesville Energy

St. Landry Parish Solid Waste Disposal District St. Landry Parish Solid Waste Disposal District

PUGET SOUND ENERGY Cedar Hills Landfill Recovery Gas Project

Element Markets Renewable Energy, LLC Johnstown Regional Energy - Raeger

Element Markets Renewable Energy, LLC Blue Skies Energy

Element Markets Renewable Energy, LLC Johnstown Regional Energy - Southern Alleghenies

Element Markets Renewable Energy, LLC Johnstown Regional Energy - Shade

Montauk Energy Holdings, LLC GSF Energy, LLC - McCarty Road LFG Recovery Facility

Montauk Energy Holdings, LLC GSF Energy, LLC - Rumpke LFG Recovery Facility

GHI Energy, LLC Fort Bend Landfill Gas Recovery Project

City of Riverview Riverview Land Preserve

JDP Renewables, LLC JDP Renewables, LLC

WESTSIDE GAS PRODUCERS, LLC Westside Gas Producers, LLC

East Texas Renewables, LLC East Texas Renewables, LLC

PINNACLE GAS PRODUCERS, LLC Pinnacle Gas Producers, LLC

Cambrian Energy/South-Tex Fort Smith Treaters LLC Cambrian Energy/Southtex Fort Smith Treaters, LLC

EIF KC LANDFILL GAS LLC EIF KC Landfill Gas LLC

SENECA ENERGY II, LLC Seneca Energy

LES Renewable NG LLC LES Renewable NG LLC

CERF Shelby LLC CERF Shelby LLC

MONTANA-DAKOTA UTILITIES CO. Billings Regional Landfill Biogas Project

COMPLEXE ENVIRO PROGRESSIVE LTEE Complexe Enviro Progressive Ltee

EM Gas Marketing, LLC Fresh Kills Landfill

Element Markets Renewable Energy, LLC Ameresco San Antonio Biogas

LEGO V, LP Lego V, LP

PENDING REGISTRATIONS

TOTAL 32,585,135 87,016,415

Information Withheld - Claimed as CBI

Information Withheld - Claimed as CBI

Information Withheld
Unlike other facilities registered under the RFS program, the volume listed as the total actual 

peak capacity for cellulosic biogas producers is not related to a historic production volume. 

Rather, the volume listed as the total actual peak capacity is equal to the sum of all the contracts 

or affidavits the producer has in place at the time of registration for the use of CNG/LNG derived 

from biogas for use as a transportation fuel. For producers of RINs for CNG/LNG derived from 

biogas this is most often the factor that limits the number of RINs they are able to generate, and 

it is therefore used as the facility capacity for these producers. Where no value is listed in the 

total actual peak capacity field a facility capacity is estimated based on the previous RIN 

generation rates for the facility. 

The data in Table 2 serves as a starting point for projecting the number of cellulosic biofuel RINs 

likely to be generated for CNG/LNG derived form biogas in the last three months of 2015. 

However, it has two main limitations. While total peak capacities are listed, historically many 

biogas producers have generated RINs at rates lower than their listed total actual peak capacities. 

This suggests that simply using the sum of the capacities for each facility (352 million gallons) 

would significantly over-project the actual likely generation of cellulosic biofuel RINs from 

CNG/LNG in 2015 and 2016. Conversely, Table 2 lists only facilities that are currently 

registered or in the process of registering. Considering only facilities that are currently 

registered or in the process of registering does not include any volume for facilities that may 

register in the future and would under-estimate the potential for RINs generated for CNG/LNG 

derived from biogas in any new facilities successfully register and begin generating cellulosic 

biofuel RINs in 2015 and 2016.

To address these challenges EPA obtained company specific production estimates from the 

Coalition for Renewable Natural Gas (CRNG) for 2015 and 2016. The Coalition for Renewable 

Natural Gas is made up of members that develop, own, operate, and service renewable natural 

gas projects. According to the CRNG, their members produce more than 90% of the 

transportation fuel grade renewable natural gas in the United States. The company specific 

projections received from the CRNG are reproduced in Table 3 below.
Table 3

Company Projections for CNG/LNG Derived from Biogas from CRNG

* EGE stands for ethanol gallon equivalent. A quantity of CNG/LNG derived from biogas with an energy content of 

77,000 BTU

To verify the projections received from CRNG, EPA attempted to link the registered facilities to 

the list of producers or registrants in the projections provided by CRNG3. For the remainder of 

this memo we will refer to the entities labeled producer or registrant by CRNG as “parent 

companies”4to avoid confusion with the company and facility names in Table 2 above. We 

relied on publicly available information as well as comments submitted to EPA on our proposed 

2014 volume standards rule to determine which facilities are associated with the listed parent 

companies.

5

 Table 4 below shows the result of our attempt to link CRNG parent company 

information to our list of facilities. There were several registered facilities that EPA determined 

were not affiliated with any of the parent companies in the projections provide to EPA by 

CRNG. These facilities are listed in the Unaffiliated (No Parent Company) row in Table 4. 

Projections for these facilities are based on their production history and total peak capacity as 

explained in more detail below.

 

3 EPA requested information on production projections from individual facilities, and information related to the 

facilities that comprised each larger company’s estimate; however CNRG did not provide this information, 

indicating that their members were generally unwilling to share this information with EPA.

4 We do not intend to imply that the registered facilities are necessarily owned by the “parent company,” simply that 

we believe the production estimates of the parent companies include the RINs generated by the registered 

facilities associate with them in Table 4.

5 EPA-HQ-OAR-2013-0479

Producer or Registrant Production Estimate 2015 (EGE)* Production Estimate 2016 (EGE)

TOTAL 138,628,908 257,072,239

Information Withheld - Claimed as CBI
Table 4

Registered Facilities in EMTS by Parent Company

Parent Company Registered Facility Name(s)

Information Withheld – Claimed as CBI

After determining which registered facilities were associated with the various parent companies

listed in the projections provided by CRNG, EPA calculated the sum of the total actual peak 

capacities for all of the identified facilities associated with each parent company. Facility 

specific projections were made for the facilities that were determined not to be affiliated with a 

parent company. These facilities are listed individually in Tables 5 and 6 below.

6 We also 

separately calculated the sum of the total actual peak capacities of all registered facilities 

associated with each parent company that have already generated cellulosic biofuel RINs for 

CNG/LNG.

We next used the sum of the total actual peak capacities for all facilities associated with each

parent company that have already generated cellulosic biofuel RINs as an indication of whether

the projected production for each parent company was expected to come from new or existing 

facilities. If the CNRG projection for a parent company was less than the sum of total actual 

peak capacities for facilities associated with that parent company that have generated cellulosic 

biofuel RINs, we assumed that the entire CNRG projection was for existing facilities and used 

that value as the high end of the range for our production projection for the last three months of 

2015 for the parent company. If the CNRG projection was greater than the sum of total actual 

peak capacities for facilities associated with a parent company that have generated cellulosic 

RINs, we assumed that the portion of the CNRG projection relating to existing facilities was 

equal to the sum of total actual peak capacities of facilities that have generated cellulosic RINs, 

and that the additional increment in the CNRG projection was attributable to new facilities. We 

used that value to represent the high end of the range for our production projection from new 

facilities for the last three months of 2015 for the parent company. We note that because we are 

trying to project production over the last three months of 2015 and relying on actual data for the 

first nine months, the high end of the ranges projected here represent the high end of the 

annualized rate of production for the last three months of 2015, rather than the high end of the 

range of actual expected production in 2015.

 

6 Several smaller facilities were combined and listed under the Small Producer category
EPA did not use a six-month straight-line ramp-up to assess the reasonableness of production 

projections from new facilities generating cellulosic biofuel RINs for CNG/LNG derived from 

biogas as we did with other cellulosic biofuel producers. This is because the vast majority of 

“new” facilities generating RINs for CNG/LNG derived from biogas already have a significant 

history of producing CNG/LNG for non-transportation markets. All that is necessary for many 

of these companies to begin generating RINs is to register the facilities and demonstrate that the 

CNG/LNG being produced is from approved sources and is used as transportation fuel. They do 

not face the same ramp-up schedule or uncertainties as newly constructed facilities operating 

new technologies. There is, however, still a significant amount of uncertainty related to RIN 

generation from facilities that have not yet begun generating RINs. RIN generation from these 

facilities may be delayed or reduced if they are unable to verify that all or a portion of the 

CNG/LNG they produce is used as transportation fuel, or if they decide to sell the CNG/LNG 

they produce into non-transportation markets. These uncertainties can significantly impact the 

number of RINs generated by a CNG/LNG producer, and we therefore believe that projecting 

projection from these “new” facilities at the 50th percentile of the range is appropriate.

For facilities not associated with a parent company projection we calculated a projected volume 

based on an extrapolation of the cellulosic RIN generation of that facility from January 2015 –

September 2015. There were five facilities not associated with a parent company that have not 

yet generated RINs ([Information Withheld – Claimed as CBI]). We have not projected any 

production from these facilities in 2015.

The combined sum of the projected production of all of the companies or registrants and the 

unaffiliated facilities was multiplied by a scaling factor of 0.25. This was done to appropriately 

scale full year estimates of production for use over only the remaining 3 months in 2015 

(October – December), the time period for which we are projecting volumes. The sum of the 

projected volumes for new and existing facilities for 2015 from all of the parent companies, as 

well as the unaffiliated facilities, was used as the high end of the projected range for 2015 for 

CNG/LNG derived from biogas for new and existing facilities respectively. These calculations 

for each company or registrant, as well as the projections for unaffiliated facilities, are shown in 

Table 5 below. The sum of the projections for all parent companies and all facilities not 

associated with a parent company are used as the high end of the range for projecting cellulosic 

RIN generation for CNG/LNG derived form biogas for the last 3 months of 2015 for existing 

facilities (33 million gallons) and new facilities (0 million gallons). See Section IV.E of the 

preamble for more detail on how the high end of these ranges are used to project total cellulosic 

biofuel production in 2015.
Table 5

High End of the Projected Range for CNG/LNG Derived from Biogas in 2015 (Existing and 

New Facilities)

2016 Projection 

To project the range of production volumes of cellulosic biofuel RINs from CNG/LNG derived 

from biogas for 2016 we used a similar methodology to the one outlined above for 2015. As 

discussed in Section IV.F of the preamble of the final rule, we calculated the low end of the 

projected range from facilities that are currently generating RINs to be equal to the production 

from these facilities in the most recent 12 months for which data is available (October 2014 –

September 2015). For facilities that have not yet generated cellulosic biofuel RINs the low end 

of the range was set at 0. We believe this methodology produces a reasonable projection of the 

lowest volume of cellulosic biofuel likely to be produced in 2016, while at the same time 

reflecting the uncertainty related to each individual source of cellulosic biofuel.

We used the same sources of information to project the high end of the range of cellulosic 

biofuel RIN generation in 2016 as we did for 2015. For 2016 we began with parent company

projections provided by CRNG for 2016. We compared each of these volumes to the sum of the 

total actual peak capacities for all facilities that have generated cellulosic biofuel RINs

associated with that parent company. If the projected volume for the parent company was less 

than the sum of the total actual peak capacities for all of the facilities that have generated 

cellulosic biofuel RINs associated with the parent company we assumed that the full projected 

volume for 2016 was from existing facilities. If the projected production volume from a 

company or registrant for 2016 exceeded the sum of the total actual peak capacities for all of the 

facilities that have generated cellulosic biofuel RINs associated with the parent company then a 

production volume equal to the sum of the facility capacities for all of the facilities that have 

generated cellulosic biofuel RINs associated with the parent company was used as the projected 

volume from existing facilities and any volume in excess of that used as the projected volume

from new facilities in 2016. 

For registered facilities that were not associated with one of the companies or registrants for 

which EPA had projections we based our projection for 2016 on the historical RIN generation 

rate from these facilities. Consistent with our approach for facilities affiliated with parent 

Parent Company, Registrant, 

or Unaffiliated Company Capacity Sum

Capacity with 

Production

2014 

Production

2015 Production 

(Jan - Sept.)

2015 Estimate 

(CRNG)

2015 Existing 

Facilities Estimate

2015 New Facility 

Estimate

TOTAL 138,628,908 140,638,547 852,745

Information Withheld - Claimed as CBI
companies, all of the volume projected from these facilities was categorized as being from 

existing facilities since any facility from which we are projecting production in 2016 has already 

generated cellulosic biofuel RINs. The sum of the projected volumes for new (63 million 

gallons) and existing facilities (197 million gallons) for 2016 from all of the parent companies, as 

well as the unaffiliated facilities, was used as the high end of the projected range for 2016 for 

CNG/LNG derived from biogas for new and existing facilities respectively. Table 6 below 

summarizes these calculations and shows the projected high end of the range for CNG/LNG 

derived from biogas in 2016 for both existing and new facilities. See Section IV.F of the 

preamble for more detail on how the high end of these ranges are used to project total cellulosic 

biofuel production in 2016.

Table 6

High End of the Projected Range for CNG/LNG Derived from Biogas in 2016 (Existing and 

New Facilities)

Parent Company, Registrant, 

or Unaffiliated Company Capacity Sum

Capacity with 

Production

2014 

Production

2015 Production 

(Jan - Sept.)

2016 Estimate 

(CRNG)

2016 Existing 

Facilities Estimate

2016 New Facility 

Estimate

TOTAL 257,072,239 197,086,852 62,847,771

Information Withheld - Claimed as CBI