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  8

Pine Street

Burlington,

VT

05401-4891

802-658-0300 * 802-865-7386 TTY /Voice)

Fax: 802-865-7400

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.

July 12 2013

Re: Docket ID No. EPA HQ OAR 2012 0401

Notice

o

Proposed Rulemaking, 78

Fed Reg

36042

Regulation o 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 o Fuels and Fuel Additives: RFS Pathways

II

and Technical

Amendments

to

the RFS2 Standards. BED writes in furtherance o 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

o

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 o 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

o

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

5

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-2012-

0401, 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

s

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, s 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 s 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 s a Cellulosic Biofuel.

III. Inclusion

of

a athway 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 s to whether renewable electricity resulting from the combustion of woody

biomass qualifies s 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,

s

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 ofRIN 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

an uckley

Tom Buckley

Manager, Customer Energy Services

Burlington Electric Department

585 Pine Street

Burlington, Vermont 05401

802-865-7339

www.burlingtonelectric.com