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NATIONAL - CWPMA - THOUGHTS ON THE EPA E- RINS PROPOSAL

The EPA is proposing the below –

 

As ratepayers continue to bear the burden of government mandates on energy providers with through higher fuel costs or emissions reduction mandates on utilities (where generally those investments are recoverable at the guaranteed rate of return) we now have this proposal that should make any station owner think twice about installing E.V. Charging.

So utilities  are now going to be able to directly compete and put in Charging stations to generate RINS and double dip on the credit and regulated rate of return all at the consumer’s costs. In order to Cover the OEM’s investments….talk about socialization… meanwhile we can’t even put solar panels on our stations to self-generate power for E.V.’s under the production cap without putting in battery storage systems.  

Awesome concept  from the EPA here and ratepayers are going to get screwed again.

 

EPA’s E Rin proposal -

The EPA’s proposed approach for eRINs would allow vehicle original equipment manufacturers (OEMs) to generate eRINs based on the light-duty electric vehicles they sell by establishing contracts with parties that produce electricity from qualifying biogas. Under the proposal, eRINs would represent the quantity of renewable electricity determined to be used by both new and previously sold (legacy) light-duty vehicles for transportation, provided that sufficient renewable electricity has been produced and contracted by the OEM. The proposal would allow quantifying renewable electricity produced and put on a commercial electrical grid serving the conterminous U.S. to be contracted for eRIN generation so long as the OEM demonstrates that the vehicles it produced have used a corresponding quantity of electricity. Under the proposed approach, EPA would establish requirements for biogas generators and electricity producers, but only an OEM would be allowed to generate the eRIN, though the agency said the value of the eRIN would be expected to be distributed after its generation amongst multiple parties.

Alternative approaches discussed by the EPA include those allowing producers of renewable electricity to generate eRINs, allowing public access charging stations to generate eRINs, allowing independent third parties to generate eRINs, and a number of hybrid approaches that would allow multiple parties to generate eRINs.

The proposed rule specifies that qualifying renewable electricity under the RFS program must be generated from a feedstock that qualifies as renewable biomass under Clean Air Act Section 211(o)(1)(I). Other forms of renewable electricity, such as solar, wind and hydropower, do not qualify as renewable electricity or renewable fuel under the RFS program.

The EPA is also proposing to revise the equivalency value for renewable electricity in the RFS program from the current value of 22.6 kilowatt hours (kWh) per RIN (kWh/RIN) to 6.5 kWh/RIN. “We believe the change would more accurately represent the use of electricity as a transportation fuel relative to the production of biogas,” the agency said in the proposed rule.

The EPA is proposing for eRIN provisions of the rule to become effective starting on Jan. 1, 2024. The proposed cellulosic RVOs for 2024 and 2025 reflect the agency’s projected volumes for eRINs during those two compliance years.