585 Pine Street

Burlington, VT 05401-4891
802-658-0300 * 802-865-7386 (TTY /Voice)
Fax: 802-865-7400

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:

Burlington Electric Department (BED) appreciates this opportunity to comment on the
U.S. Environmental Protection Agency's ("EPA") proposed rule published June 14,
2013, entitled "Regulation of Fuels and Fuel Additives: RFS Pathways II and Technical
Amendments to the RFS2 Standards." BED 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, BED applauds the proposed approval of
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 of electrified transportation. BED,
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 of 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 woody biomass used to produce renewable
electricity and biogas from waste digesters and liquefied/compressed natural gas used to

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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.
Business models that create a favorable return on investment are critical to the
deployment of 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 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 President's goal of 1 million electric
vehicles on the road by 2015.
Developing these pathways and enabling the generation of RIN s from these sources
enable wider deployment of electric vehicle charging infrastructure and promote
integration of renewable power 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, BED offers the following comments below.

I.

Description of BED's Renewable Electricity and Biomass Activities and its Potential
Role in Powering Vermont's Transportation Network

Burlington Electric Department

is the municipal electric
utility for the City of Burlington and the Energy Efficiency Utility, providing energy
efficiency services within Burlington. BED serves 16,000 residential and 3,600
commercial customers and has a strong emphasis on energy efficiency and renewable
energy. The City of Burlington, which has strong carbon reduction goals in its Climate
Action Plan, is very interested in promoting electric vehicles. Transportation accounts for
close to 50 percent of the GHG emissions within Burlington. In 2012 Burlington used 5.3
percent less electricity than in 1989, the year before the Energy Efficiency Bond was
passed, and has a goal of being 100 percent renewable within a few years. BED is a 50
percent owner of the 50 MW McNeil Wood Chip-Generating Station, which opened in
1984 and is located about a mile from the downtown. The wood is all sustainably
harvested and abides by strict state harvesting standards. Because of our renewable
energy goal and goals for electric vehicles, we have the hopes of greatly reducing GHG
emissions from the transportation sector within Burlington over the short term.
In addition to its woody biomass resources, Vermont currently has 15 farm-based waste
digesters that process and collect the biogas emanating from waste generated on the
farms. Presently, all of these facilities combust the biogas that is collected on farm to

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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 of Vermont 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.
Vermont is home to the 50 MW McNeil Wood-Chip Station and the 25 MW Ryegate
Station. These facilities produced over 325,000 MWh of electricity in 2012. 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 a memorandum drafted by EPA in support of the pathway for renewable electricity

from landfill biogas, EPA stated:
The proposed lifecycle analysis of renewable 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, there
are no emissions associated with transportation of the renewable
electricity (although 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
em1ss10ns. EPA implicitly recognized the equivalency of 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. As 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 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 BED 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, BED 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. BED believes that this should not be a difficult determination to reach as
1

U.S. Environmental Protection Agency, Memorandum to Air and Radiation Docket EPA-HQ-OAR-20120401, Support for Classification ofBiofuel Produced from Landfill Biogas as Cellulosic Biofuel and
Summary ofLifecycle Analysis Assumptions and Calculations for Biofuels Produced from Landfill Biogas
(May 20, 2013).

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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 of the reductions necessary to qualify for RIN generation.
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.
BED 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 content of waste digester biogas will take longer than it
will take to finalize the renewable electricity pathway generally, BED encourages EPA to
move forward with finalizing a pathway for renewable electricity from waste digester
biogas as an Advanced Biofuel alongside its finalization of renewable electricity from
landfill biogas as a Cellulosic Biofuel.

III.

Inclusion of a Pathway for Renewable Electricity from Woody Biomass

Additionally, BED strongly encourages broadening the definition of renewable electricity

and the development of 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 of woody
biomass qualifies as a Cellulosic, Advanced or Total Renewable Fuel is only dependent
on the associated GHG reductions.
As with the pathway for renewable electricity from waste digester biogas, BED
encourages EPA to 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 quantifying the
GHG reductions associated with using renewable electricity generated from woody
biomass. Furthermore, BED is available to meet with EPA to discuss potentially
available data that may aid in this determination.
BED 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, BED encourages EPA to move forward with finalizing a pathway for
renewable electricity from waste digester gas alongside its finalization of a pathway for
renewable electricity from landfill biogas in the event that the woody biomass pathway
requires significant analysis.

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BED believes that inclusion of RIN generation pathways for renewable electricity woody
biomass and biogas from waste digesters alongside EPA' 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,

Tan Buckley
Tom Buckley
Manager, Customer & Energy Services
Burlington Electric Department
585 Pine Street
Burlington, Vermont 05401
802-865-7339
www.burlingtonelectric.com

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