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RINs Open New Market for Landfills, But is it Stable?

The industry is both guarded and optimistic about the use of RINs for landfill gas.

In 2014 the Environmental Protection Agency (EPA) classified landfill gas as a cellulosic biofuel, a step that some industry analysts believe could blossom into a biogas gold rush. With this biofuel classification, landfill operators began leveraging assets to tap into a new market: Renewable Identification Numbers (RINs) credits.

RINs are serial numbers assigned to batches of biofuel for the purpose of tracking its production, use and trading. The credits are often purchased by oil companies, that buy them to meet certain investment thresholds on the percentage of gas produced from renewable sources.

The industry is both guarded and optimistic about the use of RINs for landfill gas. It’s uncertain whether the regulatory framework driving it will remain intact under the Trump administration. Though California and Oregon have moved forward with their own clean fuel programs, creating a healthy market for landfill gas across the country. Canada may soon follow suit, project some stakeholders.  

For now, “Federal law mandates year over year that [oil companies’] total fuel portfolio have greater shares of cellulosic biofuel. That’s why so many [landfills] are getting into transportation fuel. We have a high- value commodity that big oil companies need,” says David Cox, director of operations for the Coalition for RNG. According to the Coalition’s records, about 30 landfills are selling RINs for transportation fuel as of January 2017.

RINs can be carried over, or oil refineries and other obligated parties can trade them once they meet their requirements. This in itself could possibly create a market, believes Brian Lips, energy policy project coordinator for North Carolina Clean Energy Technology Center.

“It’s not hard to find oil companies to buy RINs. If you can generate them and the volume [of gas] you make justifies the investment, you have a project,” says Shashi Menon, managing partner at EcoEngineers, consultants that support landfills in entering the RINs marketplace.

But, he adds, this space is heavily regulated and audited. Getting RINs-certified; launching a viable project; and proving oneself to scrutinizing potential takers is money and time intensive.

“You must be registered with EPA and have quality assurance protocol in place. Then oil companies have confidence that your RINs are valid and you are vetted by the EPA,” says Menon.

Third-party companies like EcoEngineers verify gas production and consumption and RINs generation while walking potential sellers through the regulatory maze.

They do feasibility analyses, considering equipment or vendor selection, evaluating quality of gas and interconnection costs.

EcoEngineers puts the quality status on RINs; showing they have been vetted by a third-party approved by EPA. And the company sets up systems for RINs sellers to track, manage and report their data showing biogas production and volume injected into the pipeline.

Currently EcoEngineers has just over 12 projects affiliated with landfills whether they are considering projects, pursing registration through EPA, or are already independently operating.

Landfill owners can bolster their chances for success if their sites are located near existing pipelines. They also can prove themselves by first fueling their trucks with their own gas or selling it to a municipality.

Wisconsin’s Dane County has approved an $18 million investment in a pipeline project, and its reason to pursue funds was to go after RINs, says John Welch, solid waste manager, Dane County Public Works.

The county has sold electricity from its gas to the local utility for years.

“But our agreement is ending in less than two years so we need to look at what to do with our gas again,” Welch says. “It won’t be economical to produce electricity so after getting back equipment proposals and a RINs market analysis report, we’ve decided to move forward with the  pipeline gas project.”

The installation is projected to happen throughout 2018.

There is risk in making this transition.

“The fear is with this new presidential and EPA administration it may be decided the market is not strong enough to maintain these goals [tied to required renewable fuel use],” Welch says. “The flip side is RINs [are] part of the same program that mandates oil producers to use a certain percentage of ethanol. And Trump has been vocal about his support of ethanol. So if the ethanol requirement remains in place, it could be good.”

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