The American Biogas Council (ABC) has criticised the US Environmental Protection Agency's final Renewable Volume Obligations (RVOs) for 2026 and 2027, warning the targets will constrain markets and undercut opportunities for livestock farmers.
ABC executive director Patrick Serfass said the agency had diverged from longstanding methods and abandoned statutory guidelines by estimating D3 RIN volumes based on projected renewable natural gas (RNG) end-use constraints rather than actual production capacity, and had also significantly underestimated real-world demand.
D3 RIN production has grown an average of 20% per year since 2020, with 2024 seeing record growth of 31%. The final RVOs imply growth of just 12% for 2026 and 5% for 2027.
Serfass said the delay in issuing the rule had already slowed project development, raised financing costs, and stalled rural investment.
He added that the final rule had also failed to reallocate credits from waivers to D3 RIN targets and had taken steps back on biogas-to-electricity eligibility.
He said: 'When EPA undershoots the RNG market, it directly diminishes economic opportunities for anyone trying to turn these wastes into value. And in the way the RFS market works, the impact on US farms may be the worst.'
The ABC is now calling on the EPA to use the forthcoming Set 3 rulemaking to correct course, setting D3 volumes that reflect actual production and support continued growth.
Serfass said: 'The agency should set D3 volumes that reflect actual production, support continued growth, and fully unlock biogas as a reliable source of American-made energy, fertiliser, and income for farmers, rural communities, and any sector with organic waste available to be recycled.'
EPA fuel targets ‘fail to represent real-world biogas growth’, says industry
