Category: Insights

Project Spotlight: American Biogas Council

Project Spotlight: American Biogas Council Carbon Accounting Tool for Biogas

 

This year, the American Biogas Council (ABC) launched the Carbon Accounting Tool for Biogas (Biogas CAT) to bring consistency and transparency to carbon intensity (CI) calculations for biogas and renewable natural gas (RNG) projects. Developed with EcoEngineers, an LRQA company, the tool addresses a major gap in voluntary carbon markets, where buyers and developers have lacked a unified, science-based way to compare emissions benefits.

Biogas projects have long faced challenges communicating their climate impact. Existing tools don’t fully capture biogas pathways, and smaller developers often lack the resources to calculate CI reliably. The Biogas CAT solves this by offering a simplified, publicly available Excel-based calculator built on life-cycle analysis principles and shaped through extensive industry input.

The result is a trusted, accessible framework that helps both developers and buyers make informed decisions. As ABC Executive Director Patrick Serfass notes, “Our goal is to empower developers and buyers with a tool that brings consistency, transparency, and confidence to emissions reporting.” EcoEngineers’ President, Brad Pleima, adds, “The Biogas CAT is about delivering clarity and consistency to a growing but fragmented market. The Biogas CAT is a foundational step toward unlocking the full environmental and economic potential of biogas.”

The Biogas CAT is free, public, and available now. It represents a major leap forward for biogas developers, voluntary buyers, and policymakers seeking credible, comparable emissions data. You can access the tool and the full methodology on the American Biogas Council website.

Read the full case study here.

 

How Regulatory Volatility Creates Strategic Advantages for Climate Projects

The following is an article originally published by Carbon Herald on December 17, 2025.

By Roxby Hartley, Ph.D., Climate Risk Director, EcoEngineers

The interplay between regulatory frameworks and voluntary carbon markets (VCMs), systems in which organizations and individuals buy carbon credits to offset their greenhouse gas (GHG) emissions beyond regulatory requirements, presents both challenges and opportunities for climate action. As political winds change and regulatory landscapes shift, voluntary markets are increasingly serving as effective bridges, helping maintain momentum in emissions-reduction efforts and providing significant risk mitigation for climate projects.

VCMs can effectively fill regulatory gaps, particularly during periods of policy uncertainty or regulatory rollbacks, while providing stability in valuation.

The Shifting Landscape of Climate Regulation

Climate policy exists in a state of constant flux. While the global trajectory has historically pointed toward increased regulation of GHG emissions, recent developments demonstrate that this path is rarely linear and increasingly unpredictable. Administrative changes, legal challenges, and shifting political priorities can create significant uncertainty in regulatory frameworks and project value. This regulatory volatility presents a particular challenge for climate projects, such as renewable energy installations, reforestation efforts, and methane capture projects, which often require long-term planning and substantial upfront investment. However, this challenge also presents an opportunity for VCMs to provide stability and maintain progress toward emissions reduction goals when regulatory frameworks are not reliable.

Regulatory surplus, a key concept in what is known as carbon market additionality, traditionally refers to emission reductions that exceed the regulatory requirements. However, in today’s increasingly volatile policy environment, this concept becomes more complex. When regulations become uncertain or face sudden rollbacks, the definition of what constitutes “surplus” becomes less concrete. Moreover, relying on income from a regulatory structure carries an increased risk rating, which grows over time.

Financial and Regulatory Additionality Arguments

A unique opportunity exists in today’s carbon markets, particularly for U.S.-based projects, due to the policy uncertainty that still exists even after the passage of the One Big Beautiful Big Act (OBBBA). In addition, the White House initiated a withdrawal from the Paris Agreement and revoked established climate commitments. These reversals create opportunities to strengthen additionality claims:

  • Enhanced Regulatory Surplus Arguments: The current regulatory uncertainty provides project developers with stronger claims of regulatory surplus. When regulations are in flux or face potential rollbacks, projects can more easily demonstrate they exceed what would otherwise be required by law.
  • Clearer Financial Additionality Demonstration: The combination of policy hostility and regulatory uncertainty creates investment conditions that strengthen financial additionality arguments. It is particularly valuable for projects with marginal economics that struggle to demonstrate additionality in more stable policy environments. With elevated risk premiums demanded by investors due to policy uncertainty, projects can more convincingly demonstrate that carbon credit revenue is necessary to overcome investment hurdles that would otherwise prevent implementation. One recent example is the postponement of the International Maritime Organization’s (IMO) Net-Zero Framework, following opposition from the U.S. and Saudi Arabia to the proposed carbon-fee system.

The Temporal Value of Voluntary Markets

VCMs demonstrate value in their ability to act quickly and maintain continuity across regulatory changes. While government regulations often face lengthy implementation timelines and potential delays, voluntary markets can respond more rapidly to emerging opportunities by:

  • Earning Benefits Now: Voluntary markets enable projects to begin generating verifiable emission reductions while regulatory frameworks are in flux.
  • Grandfathering Methodologies: Typically, methodologies incorporate provisions that allow projects to continue using their original methodologies for extended periods, typically up to 10 years. This grandfathering approach provides stability for project developers and investors.
  • Preparing For the Future: By establishing verified emission reductions ahead of regulatory requirements, projects can build track records that may prove valuable under future regulatory scenarios (such as the European Union’s Carbon Removal Certification Framework (CRCF), now adopting carbon dioxide removal methodologies).

Future Perspectives: The Evolving Role of Voluntary Markets

As climate policy continues to evolve, VCMs are likely to remain important, even as regulatory frameworks expand. Their ability to innovate, respond quickly to changing conditions, and maintain continuity during political transitions suggests an enduring role in global climate action.

Looking forward, VCMs may increasingly serve as testing grounds for new methodologies and approaches, helping refine practices that regulatory systems could later adopt. This innovation function complements their role in maintaining progress during regulatory uncertainty.

Key Takeaways

  • Regulatory uncertainty creates unique opportunities to strengthen regulatory surplus arguments.
  • Policy volatility establishes clear financial barriers that enhance additionality claims.
  • Projects can more easily demonstrate that they exceed common practice in unstable policy environments.
  • Regulatory reversals provide concrete evidence to support both regulatory and financial additionality arguments.

Conclusion

The current regulatory volatility presents a significant opportunity for project developers to strengthen additionality claims in VCMs. Far from creating barriers, the unpredictable policy environment establishes arguments for both regulatory surplus and financial additionality. When regulations can change abruptly or be reversed entirely, projects can more convincingly demonstrate they exceed regulatory requirements. Similarly, the legitimate investment barriers created by policy uncertainty strengthen financial additionality arguments by providing clear evidence that carbon credit revenue is necessary to overcome these barriers.

About the Expert

Roxby Hartley, Ph.D., is the Climate Risk Director at EcoEngineers. With more than a decade of experience in scientific research, development, and management of low-carbon energy substitutes, Dr. Hartley combines a passion for environmental issues with deep scientific knowledge and a logical ability to analyze regulations for inconsistency and strategic opportunities. He ensures client compliance within regulated markets such as the Renewable Fuel Standard (RFS), California’s Low Carbon Fuel Standard (CA-LCFS), voluntary carbon markets (VCM), and credit monetization requirements. Dr. Hartley’s work applies scientific principles, analytical skills, and critical thinking toward innovative and customized solutions to advance the development and growth of the low-carbon fuels industry.

For more information about our VCM services and capabilities, contact: 

Roxby Hartley, Ph.D., Climate Risk Director | rhartley@ecoengineers.us

 

About EcoEngineers

EcoEngineers, an LRQA company, is a consulting, auditing, and advisory firm exclusively focused on the energy transition and decarbonization. From innovation to impact, EcoEngineers helps its clients navigate the disruption caused by carbon emissions and climate change. Its team of engineers, scientists, auditors, consultants, and researchers live and work at the intersection of low-carbon fuel policy, innovative technologies, and the carbon marketplace. For more information, visit www.ecoengineers.us.

Moving Forward After COP30: Driving Transparency in Clean Transport

The following is an article originally published by LRQA on December 2, 2025.

By Urszula Szalkowska, Managing Director, Europe, EcoEngineers – An LRQA Company

The State of Play: Big Promises, Uneven Progress

Transport accounts for almost a quarter of global greenhouse gas (GHG) emissions, with road vehicles still responsible for the largest share. Ambition across the sector has grown quickly. Airlines are pursuing sustainable aviation fuel, shipping is testing new fuel pathways and parts of the road sector are accelerating electrification. Yet real world progress has not kept pace with the headlines.

Some areas are shifting, others are not. Road transport is inching forward, whereas aviation and maritime continue to face tighter constraints, from limited fuel availability to infrastructure that is nowhere near ready for large scale change. Even where promising options exist, buyers often hesitate because the underlying evidence is inconsistent, hard to compare or difficult to verify.

The scrutiny is increasing. Regulators, investors and customers want clearer assurance about what makes a fuel genuinely sustainable and how its emissions have been measured. Without that shared understanding, projects that look viable on paper run into delays when claims cannot be substantiated.

After COP30, the sector is not short of ambition. What it lacks is confidence that sustainability claims are grounded in reality. Stronger definitions, better data at the start of the value chain and credible assurance will determine whether clean transport now accelerates or continues to stall.

A Better Route to Decarbonisation: Three Steps, Not One

Too often, policy has focused on targets first and rules second. After COP30, it is time to invert the sequence.

Step 1: Agree what is genuinely sustainable.

The starting point is the sustainability of feedstocks and energy sources. We need a common, science-based understanding of which resources can reasonably be considered sustainable and under what conditions. This means looking beyond carbon to their impact on biodiversity, land use, air quality and human and ecosystem health.

Step 2: Define clear rules and limits.

Once feedstocks are agreed, we need to define the limits and characteristics they must meet. These include acceptable carbon intensity ranges, safeguards on land and water and transparent, auditable methods for verifying compliance. This work must be carried out through a wide, open, global process involving scientists, industry and civil society. COP30 has shown the value of such collaboration and the need to continue it.

Step 3: Set ambitious and realistic goals.

Only when the foundations are in place should we set targets and timelines. If ambition is informed by strong scientific, industrial and environmental evidence, it can be stretching without being unrealistic. It also allows industry to prepare, anticipate trade implications and invest with greater confidence that standards will remain stable.

This sequence sounds straightforward, although it is very different from how many regimes have evolved. The consequences of reversing it are also clear, including the emergence of unintended incentives such as unsustainable imports that exploit loopholes in current systems.

Certification and Chain of Custody: Learning from Experience

Europe has often been considered a forerunner in sustainable fuel rules. Regulations on renewables, fuel quality and vehicle emissions have shaped global markets. Certification schemes were expected to provide robust verification that ensured biofuels and other renewable fuels met strict sustainability and traceability standards.

In practice, progress has been mixed. Issues such as the rise in reported imports of used cooking oil from parts of Asia highlight the challenges. The volumes claimed were not plausible and evidence suggests that other feedstocks were being misclassified to access incentives. Certification schemes did not prevent this, undermining trust and prompting accusations of greenwashing.

This experience illustrates that certification must go beyond minimum compliance. It must test whether volumes, sourcing and claimed impacts are plausible and whether the value chain can be reconstructed from raw material to delivered fuel. LRQA is entering this space with a commitment to thorough, evidence-based verification that strengthens confidence in how fuels are produced and traded.

Data Quality and GHG Numbers: Focus on the First Point in the Chain

The most critical point in the value chain is the origin of the feedstock used to produce low carbon fuels. If unsustainable biomass is created solely to meet targets, or if waste streams expand artificially because any volume can be absorbed, the climate benefit evaporates.

This is why the strictest surveillance and verification must be applied at the start of the chain. This is where we can prevent incentives that encourage the wrong outcomes, prioritise locally sourced materials and ensure that waste and residue streams are genuine. Once this first link is secure, later stages can be supported by systems level assurance and well documented mass balance or book-and-claim approaches.

For producers and buyers, credible data in 2025 should include transparent life-cycle boundaries, GHG verified emissions and traceable, auditable material flows. Better data at the start does not slow progress. It accelerates it, because everyone in the chain is working from the same facts.

Green Claims, Credibility and the Case for Simple Common Rules

Regulators and courts are increasingly challenging sustainability claims that lack clear evidence. Recent cases in aviation and energy show that claims about green or carbon neutral services must be backed by robust data, transparent methodologies and a clear distinction between emission reductions and offsets.

The European Union’s work on a Green Claims framework, although currently paused, points towards a sensible direction of travel. Claims should be substantiated, independently verified and presented transparently. Generic terms such as eco-friendly should not be used unless supported by evidence. Transport can benefit from the same approach.

Public claims and access to finance should only be possible when they meet defined criteria for substantiation, verification and transparency. This does not mean more labels. It means fewer, clearer and more reliable rules.

What Clean Transport Needs After COP30

Now that COP30 has concluded, attention must shift to the practical steps that will make transport decarbonisation credible and scalable. Three priorities stand out:

1. Common sustainability requirements for feedstocks

A shared global minimum for what counts as a sustainable feedstock, covering carbon intensity, biodiversity, land use and social safeguards.

2. A common basis for substantiated decarbonisation claims

Clear rules for how low carbon claims are substantiated, verified and communicated, including lifecycle boundaries and expectations for disclosure.

3. Practical pathways to mutual recognition

Mechanisms that allow verified claims to be recognised across borders without complete rework, provided they meet agreed minimum criteria. This would reduce friction and give financiers the confidence to link terms to assured outcomes.

These steps are essential for turning pilots into scale across aviation, shipping and heavy road transport.

The Role of Assurance: From Loopholes to Momentum

Assurance is sometimes viewed as a constraint. In reality it is how we close the loopholes that have undermined trust and slowed progress. When assurance is embedded early it strengthens traceability, clarifies which feedstocks and pathways are in scope and provides a reliable basis for compliance with evolving green claims rules.

It is also how financiers and buyers gain confidence that projects will deliver. Verified milestones and GHG assured outcomes create a clearer risk picture and can improve commercial terms.

EcoEngineers and LRQA’s role is shifting in response. By bringing together GHG verification, sustainability assessment and robust certification, we can help fuel producers, operators and buyers convert good intentions into delivery that stands up to scrutiny long after the press release has faded.

What this Means for Business

For airlines, shipping lines, road fleet operators and fuel producers, the message is clear. Build credibility into the plan.

  • Begin with feedstock sustainability.
  • Align with emerging common rules.
  • Strengthen certification and traceability.
  • Link finance and contracts to verified outcomes.
  • Use independent assurance as a strategic tool for reducing risk and accelerating progress.

Now that COP30 has closed, the priority is shifting decisively from ambition to delivery. The transport sector has the will to move. With clearer rules, stronger data and credible assurance, it now has the opportunity to move at speed.

For more information about how we help clients navigate the energy transition in Europe and globally, contact:

Urszula Szalkowska, Managing Director, Europe | uszalkowska@ecoengineers.us

 

About EcoEngineers
EcoEngineers, an LRQA company, is a consulting, auditing, and advisory firm exclusively focused on the energy transition and decarbonization. From innovation to impact, EcoEngineers helps its clients navigate the disruption caused by carbon emissions and climate change. Its team of engineers, scientists, auditors, consultants and researchers live and work at the intersection of low-carbon fuel policy, innovative technologies, and the carbon marketplace. For more information, visit www.ecoengineers.us.

About LRQA
LRQA is the leading global risk management partner. Through its connected risk management solutions, LRQA helps clients navigate an evolving global landscape to keep organizations one step ahead. From certification and cybersecurity to safety, sustainability and supply chains, LRQA works with clients to identify risks across their businesses. LRQA’s team of experts then creates smart, scalable solutions, tailored to help organizations prepare, prevent and protect against risk.

Through relentless client focus, backed by decades of sector-specific expertise, data-driven insight and on-the-ground specialists across assurance, certification, inspection, advisory and training, LRQA supports over 61,000 organizations in more than 150 countries. More: https://www.lrqa.com

Super Pollutants: The Hidden Multiplier in Climate Math

By Roxby Hartley, Ph.D., Climate Risk Director, Business Development, EcoEngineers

Global Warming Potential over 100 years (GWP100) is masking the urgency of super pollutant mitigation. A temporal mismatch between how we measure greenhouse gases and when their damage occurs is a problem for climate action. Super pollutants, gases that deliver intense warming in years or decades rather than centuries, are systematically undervalued by our standard metric, GWP100. GWP100 serves as the foundation for virtually all carbon accounting. It is causing a serious underestimation of the climate impacts of super pollutants, which are accelerating the cascading feedback we are starting to experience.

What Exactly is a Super Pollutant?

Super pollutants are greenhouse gases with an outsized warming impact. While carbon dioxide (CO2) and water vapor absorb infrared radiation at specific wavelengths, they leave spectral windows where heat can still escape to space. Super pollutants absorb precisely at these wavelengths, effectively closing these atmospheric escape routes and trapping heat that would otherwise radiate away.

The Intergovernmental Panel on Climate Change’s (IPCC’s) Sixth Assessment Report provides widely accepted values for GWP100: CO2 equals 1, methane ranges from 27.9 (fossil sources) to 29.8 (non-fossil sources), and refrigerants like HFC-134a have a GWP100 of 1,530.  This metric answers the question: How much warming does one tonne of gas cause over a century compared to CO2?

Super pollutants typically deliver this heat input with accelerated timelines. Methane persists for just 12 years but creates 82.5 times more warming than CO2 over 20 years (GWP20). The century-long averaging reduces the warming to 30 times, with just 12 years of intense warming followed by 88 years after the methane has long been converted into CO2. Black carbon operates on even shorter timescales—days to weeks—delivering intense warming during its brief atmospheric lifetime, though standardized GWP values remain highly uncertain due to its complex atmospheric interactions. HFCs present different dynamics. HFC-32, for example, has significantly higher warming impact in the near term than its 100-year average suggests. Every kilogram released delivers front-loaded warming as we approach and pass climate tipping points.

Timing Matters

While the immediate radiative forcing can be correctly averaged over 100 years, it ignores the cascading impacts of heating the planet now. We do not know when we will reach tipping points in the Earth’s climate. Some have likely already passed. We do know the Arctic is losing albedo as highly reflective sea ice is replaced with dark ocean (Arctic amplification). The impact of melting all that ice over 12 years instead of 100 years adds a lot of extra energy to the Earth’s system, which, according to GWP100, is heavily discounted. It cannot be emphasized enough: Early warming triggers earlier feedback.

Why do we use 100 years for averaging heating? The choice emerged from policy convenience. Policymakers needed a single metric to compare gases with vastly different lifetimes—CO2 persists for centuries, methane for 12 years, some for months. A century seems like a reasonable compromise. The Kyoto Protocol enshrined GWP100, carbon markets, national inventories, and corporate reporting. What seemed like a good choice in 1997 may now have dire consequences.

What are the Impacts of Using GWP100?

This temporal mismatch drives systematic underinvestment and misunderstanding of how the Earth’s climate is responding. The business implications are compound. Companies using GWP100 for net-zero strategies unknowingly backload their climate impact—investment decisions favoring long-term CO2 removal over immediate super pollutant reduction miss far more cost-effective near-term wins.

What Can We Do?

We should be using GWP20 as an initial step; one can have a hopeful expectation that the front-loading of methane leak abatement, the destruction of refrigerants, the prevention of black carbon release, and forestry management will be prioritized by the increased economic gains.

Ideally, we would switch from tonnes of CO2 to focusing on what really matters: reducing the heating of the Earth. A direct energy crediting system is likely to be more helpful in evaluating real project impacts, allowing for the crediting of nascent albedo-increasing projects, and slowing the headlong rush into a much hotter world.

About the Expert

Dr. Roxby Hartley specializes in integrating biodiesel and renewable diesel into regulatory markets. With over a decade of experience in low-carbon diesel substitutes, he ensures client compliance across regulatory standards like the Renewable Fuel Standard (RFS) and LCFS. Dr. Hartley applies scientific expertise to drive innovative solutions for industry growth, with extensive knowledge in biomass and low-carbon fuels. He has acquired extensive acumen in the energy and oil industry and managed operations at a California biodiesel plant.

For more information about EcoEngineers’ services and capabilities, contact:

Roxby Hartley, Ph.D., Climate Risk Director, Business Development | rhartley@ecoengineers.us

Navigating Uncertainty: Impact of the IMO Net-Zero Framework Postponement

By: Urszula Szalkowska, Managing Director, Europe, and Nathalie Danel, Account Manager, EcoEngineers

The maritime industry is at a crossroads. The International Maritime Organization (IMO) recently postponed the adoption of its Net-Zero Framework during an Extraordinary Session of the Marine Environment Protection Committee (MEPC/ES.2). While procedural, this decision has sent ripples across the global shipping ecosystem.

At EcoEngineers, we believe this moment calls not for a pause, but for preparation.

Sector Reactions: An Interruption or An Opportunity?

Industry stakeholders responded promptly to the postponement, sharing a range of perspectives and concerns.

  • The Methanol Institute emphasized that producers are ready to deliver clean fuels, but regulatory clarity via a global framework is needed to unlock investment.
  • The International Chamber of Shipping called for urgent action to avoid fragmented national regulations. It reminded that the shipping industry is committed to the IMO Greenhouse Gas (GHG) Strategy net-zero by 2050 goal.
  • The European Community Shipowners’ Associations (ECSA) stressed the importance of a strong signal to the market.
  • The World Shipping Council, INTERCARGO, and the International Association of Ports and Harbors (IAPH) echoed concerns about delays, which are leading to uncertainty and complexity.
  • The European Commission, through the Directorate-General for Mobility and Transport (DG MOVE), reaffirmed its support for ambitious global measures and urged IMO Member States to adopt the Framework without further delay.

While many see the postponement as a setback, others view it as an opportunity to refine the framework and build a broader consensus. The IMO Secretary General, Arsenio Dominguez, reminded stakeholders that “there are no winners or losers,” and encouraged constructive negotiations over the next year. Organizations like INTERTANKO call for using the delay as an opportunity to address ambiguities and improve implementation pathways.

Regardless of the IMO timeline, the European Union (EU) continues to lead with its own regulatory instruments:

  • FuelEU Maritime sets GHG intensity reduction for energy used on board ships.
  • The EU Emissions Trading System (ETS) now includes maritime transport, pricing carbon emissions, and incentivizing cleaner operations.
  • The Alternative Fuels Infrastructure Regulation (AFIR) and Renewable Energy Directive (RED III) further support the transition to sustainable fuels.

These regulatory schemes are already shaping investment decisions and operational strategies across the continent and beyond.

What Should Industry Do Now?

At EcoEngineers, we advise our clients to:

  1. Stay engaged with IMO developments and contribute to shaping the final Framework.
  2. Align with EU regulations, which are enforceable and already impacting market behavior.
  3. Invest in readiness – from fuel sourcing and certification to life-cycle analysis (LCA) and compliance systems.
  4. Collaborate across the value chain to ensure scalable, cost-effective solutions.

EcoEngineers supports maritime stakeholders with:

  • LCA and GHG modeling
  • Fuel certification and traceability, such as Roundtable on Sustainable Biomaterials (RSB)
  • Regulatory advisory and compliance strategy
  • Carbon accounting and verification

We help clients navigate both global and regional frameworks, ensuring they are not only compliant but competitive.

Summary

The postponement of the IMO Net-Zero Framework is not the end but a recalibration. The industry must continue to move forward, guided by regional regulations and driven by a shared commitment to sustainability.

At EcoEngineers, we stand ready to support stakeholders in this journey and maintain momentum into the low-carbon future of shipping.

 

For more information about EcoEngineers’ services and capabilities, contact:

Urszula Szalkowska, Managing Director, Europe | uszalkowska@ecoengineers.us

Nathalie Danel, Account Manager | ndanel@ecoengineers.us

About EcoEngineers

EcoEngineers, an LRQA company, is a consulting, auditing, and advisory firm exclusively focused on the energy transition and decarbonization. From innovation to impact, EcoEngineers helps its clients navigate the disruption caused by carbon emissions and climate change. Its team of engineers, scientists, auditors, consultants, and researchers live and work at the intersection of low-carbon fuel policy, innovative technologies, and the carbon marketplace. For more information, visit www.ecoengineers.us.

Unlocking Value from Landfill Methane Destruction

By Conner Adams, Client Advisor, Asset Development, EcoEngineers

As the voluntary carbon market (VCM) evolves to meet higher standards of integrity and transparency, landfill gas destruction remains a proven and widely supported method for reducing greenhouse gas (GHG) emissions. VCM landfill gas destruction projects collect and destroy methane, a super pollutant, from landfill gas emissions via combustion to create methane emission avoidance credits. Though not without their controversy,[1] all major methodologies for landfill gas destruction have received the Core Carbon Principle (CCP®)-approved label by the Integrity Council for the Voluntary Carbon Markets (ICVCM).

As a result of achieving the CCP®-label, the transaction volume of methane emission avoidance credits increased by 2.5 times in 2024 over the previous year, and in recent years, per credit prices for this category have risen significantly compared to nominal lows of approximately US$1.90 per metric ton ($/MT) from the prior decade to spot prices up to $8.30/metric ton in July 2024, as reported by the Climate Action Reserve (CAR). More recently, prices have cooled to a quasi-steady value of approximately $5/metric ton over the course of 2025, as reported by AlliedOffsets.

Two leading ICVCM carbon programs, CAR and ACR,[2] alone hosted over 50 landfill gas destruction projects in the United States (U.S.) as of Q1 2025 with an estimated impact of greater than 2.5 million metric tons per year of methane emission avoidance credits on average in recent years.

Untapped Domestic Opportunities to Generate Methane Avoidance Credits

Analysis of the Landfill Methane Outreach Program (LMOP) dataset published as of September 2024 by the U.S. Environmental Protection Agency (USEPA) indicates that there are 444 candidate landfills in the U.S. Candidate landfills are those defined as having the potential to support a landfill gas energy use project based on the following criteria:

  • Currently accepting waste or has been closed for five years or less,
  • Has at least one million tons of waste, and
  • Does not have an operational, under-construction, or planned landfill gas energy project.

Of the reported candidate landfills, roughly one-fourth (126 out of 444) have characteristics likely suitable for the development of a VCM project. These are landfills with the following reported characteristics that would meet CAR or ACR’s eligibility criteria:

  • Do not have an active landfill gas collection and control system in place with or without passive flares and/or perimeter gas wells,
  • Do not recirculate leachate,
  • Are not permitted as research, development, and demonstration (RD&D) landfills and thus are not bioreactor landfills, and
  • Are not located in California.

Theoretically, project developers could leverage a variety of accepted technologies at these sites to achieve methane destruction, including but not limited to combustion of landfill gas in a flare, use of landfill gas in an engine, boiler, or turbine to produce heat and/or power, or upgrade and use of the upgraded gas (also called renewable natural gas, or RNG) as compressed natural gas (CNG) or liquified natural gas (LNG) on or offsite of the project landfill.

In practice, a number of these landfills will eventually host an RNG project and participate in another mitigation crediting program such as state low-carbon fuel standard programs (LCFS) and/or the federal Renewable Fuel Standard (RFS). Projects participating in these other mitigation crediting programs may also participate in ICVCM carbon programs; however, these projects will be prohibited from generating methane avoidance credits where such claims stack with crediting periods of these other programs due to prohibitions on credit stacking.

Some of the landfills with suitable characteristics may be years away from generating economically sufficient flow volumes of landfill gas to facilitate an RNG project, or otherwise, and other sites still may never be deemed economically suitable for a beneficial use project. For these types of sites, participation in the VCM via the development of a methane destruction project may be highly suitable. Additional opportunities may exist outside of this analysis of USEPA candidate landfills, where sites do not otherwise meet the definition of a USEPA candidate landfill but possess suitable characteristics for a VCM project and do not presently host an RNG project.

Understanding Technological Barriers and Innovations

A key suitability check for a landfill gas project developer is accurately estimating the eligible gas flow to ensure financial viability. The offtake value of methane avoidance credits must sufficiently exceed the costs of installing and operating the destruction system, as well as maintaining collection and destruction systems and performing metering, monitoring, reporting, and verification (MMRV) activities to secure credit issuance.

Passive flares that exist at some sites, installed to control odors or otherwise, pose the greatest barrier to estimating eligible gas flows. Carbon programs require that any emissions destroyed by these pre-existing devices be deducted from quantified outcomes, meaning that only incremental additional destroyed gas flows collected and destroyed by the increased collection capacity installed by the project developer can be claimed for crediting purposes.

The typical method to quantify this deduction is to install and operate potentially high-cost metering technologies for at least three months, though not all passive flare types and configurations can feasibly support such integration. Alternatively, in some cases, project developers could deduct the maximum flow capacity for gas destruction that a passive flare could technically accommodate, where such information exists.

Project developers in recent years have built on these established methods to create new opportunities for landfill sites historically ineligible to participate in the VCM. For example, LoCI Controls Inc., a technology vendor and project developer headquartered in Wareham, Massachusetts, found a home for their automated collection and control system upgrade methodology with ACR and now has nearly a dozen projects accepted or in the pipeline for approval. This method allows for crediting incremental gas flows collected and destroyed at sites resulting from the voluntary implementation of new technologies that optimize wellfield tuning to capture more gas. However, this method relies upon information reported to the USEPA’s Greenhouse Gas Reporting Program (GHGRP) that is made publicly available in the Facility Level Information on Greenhouse Gases Tool (FLIGHT), which may cease to be a source for data in the coming years[3] and thus prevent the rollout of new projects.

Recommendations

If you think that your landfill site meets these eligibility criteria, EcoEngineers recommends a thorough project-level study to confirm that your site is suitable for participation in an ICVCM carbon program.

Contact EcoEngineers to understand your landfill site’s overall suitability to host a VCM landfill gas destruction project. EcoEngineers has been a leader in supporting project developers in successfully registering their landfill gas destruction projects in recent years.

Our team of experts can help you:

  • Navigate all requirements of CPP®-approved methodologies and carbon crediting programs for landfill gas destruction.
  • Determine suitability and outline key risks and rewards of any potential site for a VCM project.
  • Support the development of a Project Design Document (PDD) to ensure the project’s monitoring plan can produce monitoring reports that are compliant with all requirements to successfully pass validation/verification.
  • Quickly develop emission-reduction estimates and reports for validation/verification using our in-house proprietary models.

About the Expert

Conner Adams is a Client Advisor at EcoEngineers.  He helps clients develop renewable energy, emissions reduction, and carbon dioxide removal projects for the VCM. Among other areas, he has specialized in supporting project developers assess, design, and model landfill gas destruction projects to deliver decarbonization benefits today.

For more information about EcoEngineers’ Asset Development services and capabilities, contact:

Conner Adams, Client Advisor, Asset Development | cadams@ecoengineers.us    

 

[1] In July 2024, CarbonPlan published the article, titled “The first offset credits approved by a major integrity program don’t make the grade.” In this article, they explored additionality concerns on a sample of older CAR landfill gas projects that resumed activity after a long period of reporting dormancy. Climate Action Reserve formally rebuked these claims in a September article titled “2024 STAYING IN CHECK: Presentation of facts to counter inaccuracies in CarbonPlan’s article, titled “The first offset credits approved by a major integrity program don’t make the grade.”

[2] Formerly the American Carbon Registry.

[3] On March 12, 2025, Administrator Lee Zeldin of the USEPA announced that agency will be reviewing of the scope of the Greenhouse Gas Reporting Program (GHGRP), which mandates reporting of GHG emissions data for over 8,000 industrial point source facilities including landfills. 

IMO to Vote on Net-Zero Framework: Unlocking Opportunities for Low-Carbon Fuels in Global Shipping

Global shipping is on the verge of a major policy shift. The International Maritime Organization (IMO) is set to vote this month on its draft Net-Zero Framework, a landmark proposal that would introduce a new fuel standard for ships and establish a global pricing mechanism for greenhouse gas (GHG) emissions. This Framework, first advanced during its 83rd session of the Marine Environment Protection Committee (MEPC 83) in April 2025, presents an opportunity for adopting and scaling low- and zero-carbon fuels, creating new market and innovation incentives for both fuel producers and shipowners.

The Framework sets out ambitious emissions reduction targets that increase quickly over time, reflecting the urgency of aligning the maritime sector with global climate goals.

Beginning with modest reductions, the Framework escalates requirements sharply through the 2030s and 2040s with the target reductions relative to a 2008 reference GHG emissions level of 93.3 grams of carbon dioxide-equivalent per megajoule (g CO2eq/MJ) (well-to-wake). The use of both a Base Target and a stricter Direct Compliance Target ensures that shipowners steadily reduce emissions year by year. This rapid progression is designed to stimulate early investment in low- and zero-carbon fuels, encourage fleet innovation, and minimize the risk of delayed action that could jeopardize long-term climate commitments. The Framework also establishes the Net-Zero Fund, which will be financed by ship operators who elect to pay the CO2 price to buy compliance units instead of utilizing low-carbon fuels. The Net-Zero Fund will be distributed to those who deploy net-zero or near-net-zero technologies, including fuels with emissions of less than 19 g CO2/MJ.

Table 1: Target Emissions Reduction Levels from an IMO Reference Marine Fuel GHG Emissions Level[1]

[1] IMO Circular Letter No.5005 Draft Revised MARPOL Annex VI

The Framework will be integrated into a new Chapter 5 of Annex VI of the International Convention for the Prevention of Pollution from Ships (MARPOL), which addresses the prevention of air pollution from ships. Following approval, draft amendments to MARPOL Annex VI will be circulated to IMO Member States. Key milestones in the implementation process include:

  • October 14, 2025 (MEPC/ES.2): Adoption of amendments during the Marine Environment Protection Committee  
  • Spring 2026 (MEPC 84): Approval of detailed implementation guidelines
  • 2027: Expected entry into force, 16 months after adoption, consistent with MARPOL procedures

Challenges and Considerations

Global Implementation

While the Framework has the potential to cover approximately 97% of global maritime activity, its universal adoption and enforcement remain uncertain. Opposition from IMO Member States such as the United States (U.S.), Saudi Arabia, Russia, Malaysia, Indonesia, and Venezuela   could limit its impact. Despite these uncertainties, the Framework signals strong international support for low- and zero-carbon fuels, offering a growth opportunity even in regions with slower adoption.

Development of Guidelines

As with all new climate policies and programs, the devil is in the details. The formal adoption of the Framework could be a critical step forward; however, the development of implementation guidelines will provide the industry with necessary details on how to participate and best monetize this program. Elements such as allowed fuel production feedstocks, life-cycle analysis (LCA) methodology, compliance schedules, traceability requirements, and independent verification are key to the successful uptake of the Framework.

CO2-Based Penalties Drive Low-Carbon Fuel Adoption

Penalties remain a key mechanism for stimulating the adoption of renewable and low-carbon fuels. The Framework introduces a two-tiered penalty system based on annual emissions targets, a “Base Level” and a “Direct Compliance” level, that increase in stringency over time. Shipowners ultimately bear financial responsibility for non-compliance, emphasizing the importance of proactive emissions management. The draft Framework text indicates penalty values of $100/tonne CO2-eq for Direct Compliance units, and an additional $380/tonne CO2-eq for Base Level units. These penalty structures, combined with financial incentives, create a concrete opportunity for the low-carbon fuel suppliers to play a key role in decarbonizing the maritime shipping industry.

Expanding Pathways to Maritime Decarbonization

While the Framework’s CO2-based penalties are designed to accelerate the adoption of low- and zero-carbon fuels, it is important to recognize that fuel switching is only one part of a broader decarbonization strategy. Significant GHG reductions will also come from investments in ship redesign, slow steaming, optimized logistics and routing, improved at-dock practices, and advanced engine technologies. These measures, often referred to as “operational and technical improvements,” can deliver substantial emissions reductions and cost savings, especially when combined with low-carbon fuels. The Framework is expected to incentivize these approaches as shipowners seek the most effective pathways to compliance and cost management.

Policy Alignment with the European Union (EU) and the U.S.

The Framework and the EU’s decarbonization programs share a common objective of reducing maritime GHG emissions, but their scope and structure differ significantly. The Framework, once adopted, will apply globally, whereas the EU’s FuelEU Maritime initiative and Emissions Trading System (ETS) primarily regulate activity in European waters and on 50% of voyages to and from EU ports. The EU has already moved forward with binding requirements starting in 2025. For shipowners and fuel suppliers, this means navigating two systems with differing methodologies, fuel eligibility criteria, and compliance mechanisms. At the same time, the interaction between the two frameworks could create efficiencies, reinforcing momentum toward low- and zero-carbon fuels worldwide.

Differences in the programs will require companies to implement robust and adaptable monitoring and reporting systems. A significant potential difference concerning feedstock eligibility is that the EU excludes crop-based feedstocks and materials that can be used for food and for animal feed, whereas the Framework might permit them. This could provide an opportunity for fuels that meet the EU’s requirements to generate surplus compliance units under the Framework, potentially unlocking additional financial incentives.

Meanwhile, there is some movement in the U.S. primarily through the proposal of the Clean Shipping Act of 2025, which aims to eliminate GHG emissions from ocean shipping companies operating in the U.S. The Act directs the Environmental Protection Agency (EPA) to establish progressively stricter carbon intensity standards for marine fuels, beginning with a 30% GHG reduction by 2030 and leading to 100% by 2050. There is also a proposed bill to expand the Renewable Fuel Standard (RFS) to include ocean-going vessels. This change would enable vessel operators to receive credits, potentially creating revenue streams and narrowing the cost gap between renewable and conventional fuels.

The U.S. is certainly lagging the IMO and the EU in maritime decarbonization efforts; however, the recent proposed legislation represents a promising step forward. These measures could signal a growing interest in reducing GHG emissions from U.S. shipping, creating an additional opportunity for low-carbon fuel producers.

Conclusion

Approval of the IMO Net-Zero Framework would represent a crucial step toward decarbonizing global shipping. Companies that can adapt quickly, implement comprehensive monitoring systems, and strategically leverage incentives will be best positioned to capitalize on the opportunity presented by the growing low- and zero-carbon fuel market.

The next three years will be pivotal for the maritime sector, not only for regulatory compliance but also for accelerating the transition to a cleaner, low-carbon future on the world’s oceans.

Contact EcoEngineers to better understand the regulations, your fuel options, and their impact on your carbon intensity score at clientservices@ecoengineers.us.  

From Chaos to Clarity: Solving Emissions and Circularity Reporting Challenges

By Urszula Szalkowska, Managing Director, Europe, EcoEngineers

Across Europe and globally, companies are navigating a storm of regulatory shifts, Environmental, Social, and Governance (ESG) expectations, and operational realities. The landscape has become increasingly complex: regulations are overlapping, transparency is no longer optional, and the gap between corporate strategies and day-to-day operations continues to grow.

The Challenges We Face

  1. Regulatory complexity
    New and overlapping frameworks are creating uncertainty for industries trying to decarbonize. Consider the automotive sector, where tightened rules arrive in quick succession and compliance systems struggle to keep pace.
  2. Rising demand for ESG accountability
    Stakeholders—from investors to consumers—demand traceability and credible reporting. Renewable energy providers, for example, must not only meet volumetric or greenhouse gas (GHG)-based targets, but also demonstrate that sustainability criteria are certified, verified, and registered. Similarly, decarbonization claims in energy and industrial sectors now require rigorous proof under mandatory frameworks like the European Union (EU) Emissions Trading System (ETS), and voluntary ones such as the Science-Based Targets initiative (SBTi).
  3. Strategy vs. operations disconnect
    Ambitious goals often outpace implementation. A utility may announce a “climate positive by 2035” commitment, certified by SBTi, only to discover that newly emerging frameworks, such as EU Renewable Fuels of Non-Biological Origin (RFNBOs) for green hydrogen or the Carbon Removal Certification Framework (CRCF) for Bioenergy with Carbon Capture and Storage (BECCS), require entirely new layers of certification and verification that weren’t envisioned when strategies were set.

Which Strategic Pathway Forward?

Organizations have options for how to respond:

  • Wait for regulatory clarity – Conserve resources and learn from early movers.
    • This is a higher risk option, vacating a leadership position and potentially waiting for a clarity that may never come
  • Choose one pathway – Focus energy and gain an early market position.
    • Also carries risks – opening up a chance that the winning pathway is not ultimately picked would not be a recommended approach
  • Engage proactively – Map decision-makers, influence policy direction, and test ideas with your partners and other stakeholders. This option is often the most resilient, helping companies shape the very systems they must comply with.
    • The most pragmatic and practical approach, and one that has a proven track record of converting risk to strategic advantage

Actionable Solutions

Moving from chaos to clarity requires discipline and adaptability:

  1. Map the environment – Position your company within the broader European decarbonization strategy, considering political, economic, and sectoral contexts.
  2. Define your system – Set boundaries, clarify expected outcomes under each regulation, and assign roles inside and outside the organization.
  3. Invest in adaptable tools – Implement data management, traceability, and life-cycle assessment systems that meet today’s frameworks and anticipate tomorrow’s.
  4. Collaborate continuously – Build ongoing bridges between policy, manufacturing, and innovation teams, while monitoring regulatory shifts in real time.

Turning Complexity into Opportunity

While the pressure is high, these challenges also create opportunities. Companies that embrace adaptable systems, proactive engagement, and rigorous traceability will not just stay compliant—they will become leaders in shaping a sustainable, circular economy.

At EcoEngineers, we work alongside clients to ensure they can meet today’s requirements and prepare for tomorrow’s. By helping organizations turn compliance into a competitive advantage, we create clarity in the face of complexity.

About the Expert

Urszula Szalkowska is managing director, Europe, and leads EcoEngineers’ European practice, supporting both European-based clients and international clients doing business in the EU. Ms. Szalkowska has more than two decades of experience working in renewable energy, fuels, climate change, and transportation. She has a deep understanding of regulations, business impact, and strategic communications in the EU. She advises businesses on compliance with national regulations in EU MS and helps navigate the highly regulated renewable energy markets. Ms. Szalkowska coordinates global climate policy and regulations in the U.S. and the EU.

For more information about how we help clients navigate the energy transition in Europe and globally, contact:

Urszula Szalkowska, Managing Director, Europe | uszalkowska@ecoengineers.us

FAQs from Our Webinar, “CORSIA and Opportunities for SAF”

In a recent webinar hosted by EcoEngineers on September 10th, experts from EcoEngineers and the International Air Transport Association (IATA) focused on the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) and the opportunities for sustainable aviation fuel (SAF). CORSIA is a global program that helps airlines reduce carbon emissions by using lower-carbon fuels, such as SAF, or purchasing carbon credits. SAF is made from renewable sources and must meet sustainability standards. Most airlines currently use credits, but SAF’s role is growing.

As EcoEngineers’ Managing Director Kristine Klavers said during the webinar, “SAF is the best-known lever we have to decarbonize aviation.” The goal is to make flying more sustainable.

The session concluded with a Q&A addressing various technical and regulatory aspects of CORSIA SAF and lower-carbon aviation fuel (LCAF). Below is a brief FAQ from the presentation. You can watch the webinar on demand here. Additionally, a more detailed look at the questions asked during the webinar will be published in the coming weeks.

  1. What is CORSIA?

    CORSIA is a global market-based mechanism developed by the International Civil Aviation Organization (ICAO) to achieve carbon-neutral growth in the aviation industry.

  2. What is the main objective of CORSIA?

    The primary objective of CORSIA is to achieve carbon-neutral growth within the aviation industry based on a baseline set according to the sector’s 2019 emissions.

  3. How does CORSIA work?

    CORSIA works by setting a baseline for emissions and requiring airlines to offset emissions that exceed this baseline through the purchase of offsetting credits or the use of CORSIA-eligible fuels.

  4. Which countries participate in CORSIA?

    CORSIA is implemented by member states of ICAO, which include 193 countries. Participation is voluntary until 2027, after which it becomes mandatory for certain states.

  5. What happens if an airline does not comply with CORSIA?

    Penalties for non-compliance are determined by the member states that implement CORSIA within their respective legal frameworks. These penalties can vary by country.

  6. How are offsetting requirements calculated under CORSIA?

    Offsetting requirements are calculated based on the emissions that fall within the scope of CORSIA for a given year, multiplied by the sectoral growth factor for that year.

  7. What are CORSIA-eligible fuels?

    CORSIA-eligible fuels include SAF and LCAF. These fuels must meet specific sustainability criteria and achieve a net reduction in greenhouse gas emissions of at least 10% compared to conventional aviation fuels.

  8. What is the difference between SAF and LCAF?

    SAF is made from renewable or waste-derived sources, while LCAF is fossil-based but produced with processes that reduce its life-cycle greenhouse gas emissions by at least 10%. Both must meet ICAO CORSIA sustainability criteria and be certified by approved schemes. The key difference is that SAF is renewable, whereas LCAF is an improved fossil fuel with stricter requirements due to its origin.

  9. How is SAF certified under CORSIA?

    SAF must be certified by sustainability certification schemes approved by ICAO, such as the International Sustainability and Carbon Certification (ISCC), the Roundtable on Sustainable Biomaterials (RSB), and ClassNK. The certification process ensures that the fuel meets the sustainability criteria and achieves the required emissions reductions.

  10. What is the role of SAF registries?

    SAF registries track the production and use of SAF to ensure traceability and prevent double-counting of emissions reductions. The CORSIA registry operated by the Civil Aviation Decarbonization Organization (CADO) supports both regulatory and voluntary frameworks.

  11. How is life-cycle analysis (LCA) conducted for CORSIA-eligible fuels?

    LCA for CORSIA-eligible fuels is conducted using a specific methodology prescribed by ICAO. The analysis calculates the greenhouse gas emissions reductions on a life-cycle basis, considering all stages of the fuel’s production and use.

  12. Can new feedstocks be introduced into the CORSIA system?

    Yes, new feedstocks can be introduced into the CORSIA system if they meet the sustainability criteria and achieve the required emissions reductions. Entities can apply for default values for new feedstocks through a procedure available on the ICAO website.

For more information about EcoEngineers, SAF, LCAF, and Renewable Diesel, contact:

Kristine Klavers, Managing Director of Low-Carbon Petroleum fuels at kklavers@ecoengineers.us.

Advice to Renewable Fuels Project Developers: Do Your Due Diligence

By Edward Arnold, Asset Development Director, EcoEngineers

Every week, I read announcements about new, early-stage renewable fuel production projects. Many involve converting some novel feedstock—such as a new source of waste biomass or a new seed oil—into sustainable aviation fuel (SAF), renewable diesel, or hydrogen. Often, the core process technology, the technology provider, and the product slate are selected at a very early stage of the project.

When new project developers approach EcoEngineers for assistance with life-cycle analysis (LCA), pathway registration, compliance issues, price forecasts, or market studies, we sometimes find that the project planning process was relatively weak.

We see that the project’s process technology is chosen without thorough due diligence and a comparison of alternatives. Once we understand the project, often, our opinion is that the developer did not select the best process technology and flow scheme to generate the highest ROI from their feedstock.

Sometimes, we discover that the project developer is relying on the total installed project capital cost estimates developed by the technology licensor to determine their project economics. These cost estimates are usually unrealistically too low.

We also see that the project developer is basing their product carbon intensity (CI) score on estimates provided by the technology licensor, or they estimated it themselves. These CI estimates are often unrealistically low as well.

Sometimes we learn that the prime feedstock is not viable in the client’s main target market because of blocking regulations.

Too often, we tell ourselves, “They should have conducted a project feasibility and project strategy development study, fully independent of the inputs and opinions from a process technology provider.” 

Many of these projects run out of investor money before they get back on a realistic track to success.

During the post-mortem phase, I have been asked, “What should we have done differently?” My answer usually contains a variation of the following:

  • Evaluate the Technology: Don’t select a final process technology until you have evaluated the alternatives. Remember that the process performance yield and operability guarantees are what you should base your project financial analysis on, not the yields and operability claims that appear in a technology sales presentation.
  • Avoid Unproven Technology: Stay away from non-commercialized process technologies. Let someone else be the first licensor.
  • Watch Out for Supplier Cost Estimates: Don’t use a project capital cost estimate and a project completion time schedule estimate from a process technology supplier. They have too many incentives to low-ball the estimates. Develop the initial total installed capital cost estimates and project schedule estimates by working with independent technical consultants who have realistic data from actual similar projects.
  • Don’t Trust Technology Developer CI Scores: Avoid basing your project economics on product CI estimates from process technology suppliers. They have too many incentives to deliver an unrealistically low value, and it is unlikely their numbers were developed by LCA experts using the appropriate model. Have your product LCA analysis performed by a proven, independent LCA expert.
  • Perform In-depth Regulation Analysis: Do not assume that your renewable fuel production pathway will allow for sales in any market without performing an in-depth analysis of all the pertinent current regulations. Today’s regulatory frameworks are typically complex and are often in a state of transition.
  • Conduct Third-Party Validation: Have market experts check your credit value estimates and feedstock costs now and into the future.

EcoEngineers can help project developers with:

  • Life cycle analysis (LCA)
  • Pathway registration
  • Regulatory compliance
  • Market analysis and forecasting
  • Process technology selection (Best Available Technology)
  • Project economics development
  • Process Guarantee and Offtake/Supply Agreement reviews

Please reach out to me to discuss ways we can help you drive your projects forward.

Eco Engineers

1300 Walnut St., Suite 100

Des Moines, IA 50309

  +1 515.985.1260

  clientservices@ecoengineers.us

   

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