July 12, 2013

VIA 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. EPA-HQ-OAR-2012-0401

Notice of Proposed Rulemaking, 78 Fed Reg. 36042
Regulation of Fuels and Fuel Additives: RFS Pathways II and Technical Amendments to the RFS2
Standards

Dear Madams and Sirs:

Green Mountain Power ("the Company") appreciates this opportunity to comment on the U.S. Environmental
uel
Protection Agency's ("EPA") proposed rule published June 14, 2013, entitled "Regulation of Fuels and F
Additives: RFS Pathways II and Technical Amendments to the RFS2 Standards." The Company writes in
furtherance of the attached letter to EPA Acting Administrator Perciasepe from Vermont's delegation to the United
States Congress, dated June 27, 2013.
As with the Vermont Congressional delegation, the Company applauds the proposed approval ofa 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 tech no logy developments and recognizing the substantial benefits of 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 ofbiogas 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 of
electric transportation, which is essential to meeting national goals for reducing oil dependence and cutting GHG
emissions.

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Business models that create a favorable return on investment are critical to the deployment of electric vehicle
charging infrastructure. Public and work place 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 of electric vehicle charging and
enable a larger scale deployment of electric vehicle charging infrastructure powered by renewable electricity.
Facilitating widespread availability of electric vehicle charging infrastructure supports the Pres
ident's goal of l
million electric vehicles on the road by 2015.
Developing these pathways and enabling the generation of RINs from these sources enable wider deployment of
electric vehicle charging infrastructure and promote integration ofrenewable powe r into transportation and into the
larger grid. When these sources of electricity are used to power our vehicles, the result is reduced reliance on
imported fossil fuel, stronger local and national economies and a cleaner environment.
Specifically, the Company offers the following comments below.

I.

Description of the Green Mountain Power 's Renewable Electricity and Biagas Activities
and its Potential Role in Powering Vermont's Transportation Network

Green Mountain Power (GMP,

is an electric utility in the state of Vermont focused
on providing its customers with a balance of the most reliable, affordable, smart and clean electricity in an effort to
be the best small utility in America.
GMP employs more than 650 professionals, with annual revenues of$600 milllion. A strong investor in innovative
programs including renewable energy development, GMP created the Cow Power program to work with Vermont
fanners to inspire, fund and coordinate investment in local, baseload renewable power through fann based waste
digesters. GMP is also a partial owner of the 50 MW McNeil Wood Chip -Generating Station, which opened in 1984
and provides additional renewable, local, baseload power. The wood is all sustainably harvested and abides by the
strict state harvesting standards.
In addition, GMP continues to invest in electric vehicles and electric vehicle charging stations around the state
support our customers and be a catalyst in the Vermont to accelerate our path toward the future of transportation.

to

Currently, Vermont has 15 farm based waste digesters that process and collect the biogas emanating from waste
generated on the fanns. Presently, all of these facilities combust the biogas that is collected on farm to produce
approximately 18,000 MWh of 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 ofVennont
annually. Furthermore, the potential RIN generation revenue could be used to help finance other biogas collection
projects. Vermont has a potential of generating more electricity from waste digester biogas with the addition of a
new revenue source generated from RINs.
The State also has four facilities tha t process and combust woody biomass to produce nearly 340,000 MWh of
electricity. This electricity could be used to renewably power approximately 95,000 electric vehicles in the State of
Vermont annually.

II.

Inclusion of a Pathway for Renewable Electricity from Waste Digester Biogas

In the proposed rulemaking, EPA states that "We do not at this point have sufficient infonnation to evaluate the
lifecycle greenhouse gas emissions for production ofrenewable electricity ... from biogas from ... waste digesters.
Accordingly, we invite comments 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 of the pathway for renewable electricity from landfill biogas, EPA
stated:
The proposed lifecycle analysis ofrenewable electricity produced from landfill biogas focused on
emissions associated with production of the fuel. We did not consider any emissions from
production of the feedstock because the biogas originates from municipal solid waste. Similarly,

CREW FOIA 2014-006851-0002003

there are no emissions associated with transportation of the renewable electricity (alth ough losses
are accounted for), and no tailpipe emissions, so the only significant GHG emissions are derived
from fuel production. 1
As with the renewable electricity from landfill biogas, waste digester biogas has no emissions from: (1)
the
production of the feedstock (because the biogas originates from farm and food waste ); (2) the transportation of the
renewable electricity; and (3) tailpipe emissions. EPA implicitly recognized the equivalency of the two sources
when it provided a pathway for RIN genera tion for renewable compressed/liquefied natural gas from both landfill
gas and waste digester gas. As a result, the only potential difference in GHG emissions between renewable
electricity from digester biogas and landfill biogas should be the emissions d erived from production of the "fuel"
(i.e., combustion of 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 of 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 con duct the very minor additional analysis that would be required to detennine
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 generat ion, respectively. The Company believes that
this should not be a difficult detennination to reach as EPA detennined that the real GHG reductions resulting from
using renewable electricity from landfill biogas as a transportation fuel ranged between 96 pe
rcent (landfills that
2
Such GHG reductions are far in excess of the
flared biogas) to 765 percent (landfills that vented biogas).
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 of a pathway for renewable ele ctricity from landfill
biogas. To that end, the Company suggests that the EPA utilize the data available and models of 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 of renewable electricity.
As 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 of diet of primarily cellulosic material (e.g., hay
and alfalfa). As 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 of
whether waste digester biogas meets the definition of a cellulosic biomass. Therefore, if an analysis of the cellulosic
than it will take to finalize the renewable electricity pathway
content of waste digester biogas will take longer
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 of renew able electricity from landfill biogas
as a Cellulosic Biofuel.

III.

Inclusion of a Pathway for Renewable Electricity from Woody Biomass

Additionally, the Company strongly encourages broadening the definition ofrenewable electricity and the
development ofpathw ays 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 of woody biomass qualifies as a Cellulosic, Advanced or Total Renewable Fuel is only dependent on the
associated GHG reductions.

U.S. Environmental Protection Agency, Memorandum to Air and Radiation Docket EPA -HQ-OAR-2012-0401,
Support for Classification ofBiofuel Produced from Landfill Biogas as Cellulosic Biofuel and Smnmary of
Lifecycle Analysis Assumptions and Calculations for Biofuels Produced from Landfill Biogas (May 20, 2013).
2
Id.

CREW FOIA 2014-006851-0002004

As with the pathway for renewable electricity from waste digester biogas, the Company encourages EPA to utilize
the data available and models of the Argonne National Labo ratory 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. Furthennore, the Company is available to meet
with EPA to discuss potentially available data that may aid in this determination.
The Company recognizes that making such a pathway d etermination 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 d
igester gas alongside its
finalization of 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 as the Company
believes that inclusion ofRIN generation pathways for renewable electricity woody biomass and biogas from waste
digesters alongside EP A's finalization of a pathway for renewable electricity from landfill biogas would
significantly further the deployment of electric vehicles in Vermont and nationally, and help the United States meet
the mandates of the RFS.

Respectfully submitted,

Rebecca Towne
Green Mountain Power

CREW FOIA 2014-006851-0002005