MEMORANDUM

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

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

DATE: April 27, 2015

SUBJECT: 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 proposed 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 form 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 biomas was to review the RIN generation history for 

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

March 2015). In order to accurately assess the production history of fuels that are now eligible 

to generate cellulosic biofuel RINs for CNG/LNG from biogas we must consider not only the 

actual cellulosic biofuel RINs generated and made available for compliance, but also the 

advanced biofuel RINs generated and made available for compliance for CNG/LNG derived 

from biogas prior to August 18, 2014, the effective date of the “Pathways II” rulemaking 

allowing cellulosic biofuel RINs to be generated for CNG/LNG derived from biogas. 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

RINs Generated for CNG/LNG Derived from Biogas

Month Advanced RINs Cellulosic RINs Total RINs

April 2014 2,411,989 0 2,411,989

May 2014 2,193,478 0 2,193,478

June 2014 2,514,332 0 2,514,332

July 2014 4,340,962 0 4,340,962

August 2014 1,533,275 3,492,106 5.025.381

September 2014 0 7,552,701 7,552,701

October 2014 0 6,617,128 6,617,128

November 2014 0 6,152,005 6,152,005

December 2014 0 8,773,943 8,773,943

January 2015 0 3,962,483 3,962,483

February 2015 0 7,850,349 7,850,349

March 2015 0 7,712,870 7,712,870

Total RINs Generated 12,994,036 52,113,585 65,107,621

RINs Retired for 

Reasons Other than 

Demonstration of 

Annual Compliance1

47,882 423,260 471,142

Total RINs Available 12,946,154 51,690,325 64,636,479

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

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

for the remaining 9 months of the year (April 2015 – December 2015). Based on available 

EMTS information we have determined that 19,525,702 cellulosic biofuel RINs were generated 

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

For the last 9 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 

midpoint of the range (50th percentile) for all facilities that have previously generated cellulosic 

biofuel RINs for CNG/LNG derived from biogas, and production volume at the 25th percentile of 

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

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 0.75 (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 nine months 2015 of 48 million gallons.2 

In deriving the low end of the projected production range for the last 9 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 

 

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. 

2 For the purposes of our projections all volumes are rounded to the nearest million gallons
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 nine 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 March 31, 2015), total permitted capacity and total actual peak capacity are 

shown in Table 2 below. At the time of the assessment five 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. 
Table 2

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

Company Name Facility Name Address 1 City State 2014 

Production 

(Cellulosic)

2015 

Production 

(Jan - March)

Total 

Permitted 

Capacity

Total Actual 

Peak 

Capacity

AMP Americas LLC Renewable Dairy Fuels 5341 East 600 North Fair Oaks IN

Cambrian Energy/South-Tex Fort Smith 

Treaters LLC

Cambrian Energy/Southtex Fort Smith 

Treaters, LLC

5950 Commerce Rd Ft Smith A R

Canton Renewables, LLC Canton Renewables, LLC 4345 S. Lilley Road Canton MI

CERF Shelby LLC CERF Shelby LLC 7111 Millington Road Millington TN

City of Riverview Riverview Land Preserve 20863 Grange Rd Riverview MI

Dallas Clean Energy McCommas Bluff Dallas Clean Energy McCommas Bluff 5500 Youngblood Dallas TX

East Texas Renewables, LLC East Texas Renewables, LLC 12942 FM2767 Tyler TX

EIF KC LANDFILL GAS LLC EIF KC Landfill Gas LLC 17955 Holiday Drive Shawnee K S

Element Markets Renewable Energy, LLC Blue Skies Energy 11145 East Mount Morris Road Davison MI

Element Markets Renewable Energy, LLC Johnstown Regional Energy - Raeger 260 Laurel Ridge Rd Johnstown P A

Element Markets Renewable Energy, LLC Johnstown Regional Energy - Shade 1176 No 1 Road Cairnbrook P A

Element Markets Renewable Energy, LLC Johnstown Regional Energy - Southern 

Alleghenies

843 Miller Picking Road Davidsville P A

GHI Energy, LLC Fort Bend Landfill Gas Recovery Project 14115 Davis Estate Road Needville TX

HIGH MOUNTAIN FUELS, LLC Altamont Liquefied Biogas Plant 10840 Altamont Pass Road Livermore CA

JDP Renewables, LLC JDP Renewables, LLC 16161 Landfill Road Welsh LA

LES Renewable NG LLC LES Renewable NG LLC 4065 London-Groveport Road Grove City OH

MONTANA-DAKOTA UTILITIES CO. Billings Regional Landfill Biogas Project 5240 Jellison Road Billings MT

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

Recovery Facility

9416 Ley Road Houston TX

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

Recovery Facility

10795 Hughes Road Cincinnati OH

Montauk Energy Holdings, LLC Monroeville LFG, LLC 602 Thomas Street Ext. Monroeville P A

Montauk Energy Holdings, LLC Valley LFG, LLC 801 Raymaley Road Harrison City P A

PINNACLE GAS PRODUCERS, LLC Pinnacle Gas Producers, LLC 4220 Pinnacle Road Moraine OH

PUGET SOUND ENERGY Cedar Hills Landfill Recovery Gas Project 16645 228 Avenue SE Maple Valley W A

quasar energy group, llc Central Ohio BioEnergy, LLC 2500 Jackson Pike Columbus OH

quasar energy group, llc Zanesville Energy 6400 Maysville Pike Zanesville OH

SENECA ENERGY II, LLC Seneca Energy 2121 Route 414 Seneca Falls NY

St. Landry Parish Solid Waste Disposal 

District

St. Landry Parish Solid Waste Disposal 

District

417 Solid Waste Rd Washington LA

WESTSIDE GAS PRODUCERS, LLC Westside Gas Producers, LLC 14034 M-60 West Three Rivers MI

PENDING REGISTRATIONS

TOTAL 32,587,883 19,525,702

Information Withheld - Claimed as CBI

Information Withheld

Information Withheld - Claimed as CBI
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 nine months of 2015. 

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

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

capacities. This suggests that simply using the sum of the capacities for each facility (281 

million gallons) would significantly over-project the actual likely generation of cellulosic biofuel 

RINs from CNG/LNG in 2015. 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 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.

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

Producer or Registrant Production Estimate 

2015 (EGE)3

Production Estimate 

2016 (EGE)

Information Withheld – Claimed as CBI

Total: 157,456,726 295,024,824

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 CRNG4. For the remainder of 

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

companies”5to 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.6 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 with N/A as the parent company in Table 4. 

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

explained in more detail below.

 

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

77,000 BTU has the same energy value as a gallon ethanol and is considered an ethanol gallon equivalent 

(EGE). One RIN may be generated for every 77,000 BTUs, or EGE, of CNG/LNG produced from an approved 

facility and used as transportation fuel in the United States.

4 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.

5 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.

6 EPA-HQ-OAR-2013-0479
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.

7 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 nine 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 nine months of 2015 for the parent company.

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 

 

7 Several smaller facilities were combined and listed under the Small Producer category
“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 25th percentile of the range is appropriate.

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

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

March 2015. There were two facilities not associated with a parent company that have not yet 

generated RINs ([Information Withheld – Claimed as CBI]). Neither of these facilities has 

completed the registration process, and therefore 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 0.75. This was done to appropriately 

scale full year estimates of production for use over only the remaining 9 months in 2015 (April –

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 9 months of 2015 for existing facilities (88 

million gallons) and new facilities (37 million gallons). See Section IV.D 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, with 

modifications to take into account expected activity in 2015. As discussed in Section IV.E we 

did not project a low end of the range for CNG/LNG derived from biogas in 2016 independently, 

but rather we used the total volume of cellulosic biofuel projected to be produced in 2015 as the 

low end of the range for overall cellulosic biofuel production in 2016. 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 of the registered facilities 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 registered facilities 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 registered facilities associated with the parent 

company then a production volume equal to the sum of the facility capacities for all of the 

registered facilities 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. These new facilities could be the result of new construction, or existing 

Company, Registrant, or Unaffiliated 

Company Capacity Sum

Capacity 

w/Production

2014 

Production

2015 Production 

(Jan-Mar)

2015 Estimate 

(CRNG)

2015 Existing 

Facilities Estimate

2015 New Facility 

Estimate

Projection for 2015 (April - December) 118,092,545 87,560,159 36,892,883

Information Withheld - Claimed as CBI
landfills or digesters that are expected to begin generating cellulosic biofuel RINs for the first 

time in 2016. Our approach to attributing 2016 volumes from within the CRNG projection to 

existing facilities vs. new facilities differs from the approach we used for purposes of the 2015 

projection, in that for 2016 we used the sum of actual total peak capacities in our calculations 

rather than, for 2015, the sum of actual total peak capacities for facilities that have generated 

cellulosic biofuel RINs for CNG/LNG. We believe this approach is a reasonable method for 

projecting which facilities will have generated cellulosic biofuel RINs by the end of 2015, and

should therefore be considered existing facilities for projecting production volumes in 2016. For 

the final rule we intend to update our classification production volumes from existing and new 

facilities based on the available RIN generation data at that time.

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. If they have not yet begun production we assumed a RIN generation 

volume for 2016 equal to 50% of their total actual peak capacity. Consistent with our approach 

for facilities affiliated with parent companies, all of the volume projected from these facilities 

was categorized as being from existing facilities since they have all registered as cellulosic 

biofuel producers or are in the process of registering. The sum of the projected volumes for new 

and existing facilities 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. 

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 2016 for existing facilities (185 million gallons) and new 

facilities (120 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 2016.
Table 6

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

New Facilities)

Company Affiliations Capacity Sum

Capacity 

w/Production

2014 

Production

2015 Production 

(Jan-Mar)

2016 Estimate 

(CRNG)

2016 Existing 

Facilities Estimate

2016 New Facility 

Estimate

Total 293,768,218 185,070,050 119,521,422

Information Withheld - Claimed as CBI