EcoEngineers is a consulting, audit, and advisory firm with an exclusive focus on the energy transition. From innovation to impact, we help you navigate the disruption caused by carbon emissions and climate change.
We help you stay informed, measure emissions, make investment decisions, maintain compliance, and manage data through the lens of carbon accounting. Our team consists of engineers, scientists, auditors, consultants, and researchers with deep expertise on global fuels policy, energy and carbon markets, and alternative solutions to meet energy demands.
Eco was established in 2009 to steer low-carbon fuel producers through the complexities of emerging energy regulations in the United States. Today, our global team is shaping the response to climate change by advising businesses across the energy transition.
Together, we can create a world where clean energy fuels a healthy planet.
For a full view of our services, access the document attached.
We answer questions from our most recent webinar that covered the Inflation Reduction Act
The United States Inflation Reduction Act of 2022 (IRA) was signed into law August of last year, and industry is actively seeking ways to benefit from this landmark legislation. The U.S. Treasury is working feverishly on developing and releasing the nuts and bolts of the Act, while fielding questions from eager applicants. EcoEngineers has been monitoring the passing of the IRA, and we are engaged with the Treasury on the implementation. We gave a 10,000-foot view of this monumental law that some have said could place the U.S. in the lead of the race toward global clean energy in our webinar originally presented on March 15, 2023. Climate Risk Director Roxby Hartley, Ph.D., and Regulatory Engagement Director Lisa Hanke kicked off the event with background information and generalities surrounding the legislation. Then, they handed it off to our low-carbon fuels subject-matter experts to explain how the Act would affect their industry:
EcoEngineers had a record number of registrations and attendees on this webinar, and our experts wanted to make sure a majority of the questions asked during the event were answered. Keep in mind without proper due diligence and knowledge gathering required to answer on specific projects, we are speaking mostly in industry generalities. There is also a lot to be learned about this groundbreaking legislation, and we plan to update you when more information becomes available. Watch the full webinar here.
Stackability
Are 45Z and 45Q stackable?
Guillermo Aguirre: No, the definition of a “Qualified Facility” under the 45Z excludes facilities that are allowed to claim carbon oxide sequestration credits under 45Q.
Has it been clarified if 45Q credits can be claimed if Producer Tax Credits are also claimed? For example, if renewables diesel is produced and CO2 from the process is sequestered, can the Producer Tax Credit and 45Q sequestration credits both be claimed?
GA: No. Under § 45Z(d)(4), a qualified facility is that used for the production of transportation fuels and does not include any facility for which the credit for carbon oxide sequestration under Section 45Q was allowed.
Ethanol/Biodiesel
Do you have any insight as to how the apprenticeship requirements are expected to be interpreted for “legacy” biofuel facilities under 45Z (i.e., for past construction activities)?
McCord Pankonen: Under § 45(b)(8)(A)(ii), for purposes of § 45(b)(8)(A)(i), the applicable percentage is: (i) in the case of a qualified facility the construction of which begins before January 1, 2023, 10 percent, (ii) in the case of a qualified facility the construction of which begins after December 31, 2022, and before January 1, 2024, 12.5 percent, and (iii) in the case of a qualified facility the construction of which begins after December 31, 2023, 15 percent.
What do domestic production requirements mean for D4 RIN energy credit modeling un the U.S. Renewable Fuel Standard?
MP: Participants in any RIN program are able to participate in the IRA tax incentives. This should not require any changes to D4 RIN modeling.
Regarding utilization: Would it be possible to capture CO2, optimize to CO then use the CO to make carbon neutral transportation fuels and qualify for the $60/tonne tax credit over 12 years?
MP: The term “utilization” is a question that remains to be clarified in terms of the IRA. It is anticipated that the definition of “utilization” will determine if tax incentives are applicable to novel process technologies implemented by biofuel producers. More to come on this topic from the US IRS.
Do you think the IRA will make underground sequestration Class 6 application easier to be approved?
MP: Nothing immediate. However, if Class 6 applications increase and to ensure tax incentives can be realized, this could drive change.
Hydrogen
Can you please expand on the prevailing wage and apprenticeship requirement? For green hydrogen, do the electrolyzers cell stacks need to be manufactured in the U.S.?
Tanya Peacock: For the prevailing wage and apprenticeship requirement, IRS issued its guidance on Nov. 30, 2022. Under 45V – Clean Hydrogen Production Tax Credit, there is no requirement for the electrolyzers to be manufactured in the U.S. Rulemaking by the IRS is ongoing.
Is it more profitable to convert to hydrogen from an existing RNG facility?
GA: This would require a full scope of work. Feel free to reach out to clientservices@ecoengineers.us to be put in touch with someone to help.
What carbon intensity (CI) calculation methodology on hydrogen production will be used for 45V?
TP: A well-to-gate life-cycle analysis using the Argonne GREET model. We are still waiting for additional guidance from the IRS on upstream boundaries and the use of renewable energy credits or RECs.
Proposed changes to the California Low Carbon Fuel Standard (LCFS) imply that hydrogen produced from fossil natural gas with 96+% capture/sequestration will not qualify for LCFS credits. Isn’t that counterproductive, as California also seems to favor CO2 sequestration?
TP: It will depend on the CI score and meeting the requirements for CCS.
Sustainable Aviation Fuel (SAF)
Do we expect some HVO production to be displaced by HEFA/SAF before 2025?
Kristine Klavers: It depends on the economics of each facility, reflecting both feedstock availability and local, federal and for SAF even global financial incentives.
Regarding the Sustainable Aviation Fuel tax credit, it appears it has to be domestically produced to get the credit. Do imports qualify for SAF tax credit?
Lisa Hanke: Under § 40B(c), a qualified mixture means a mixture of sustainable aviation fuel and kerosene, but only if— (1) such mixture is produced by the 7 taxpayer in the United States (defined in § 7701(a)(9) of the Code to mean the states and the District of Columbia).
Will neat SAF imported into the US and blended in the US facility benefit from the 45Z?
KK: Unlikely, as the qualified production facility has to be in the U.S.
Are there any comments or information on the credits that are going to be available for SAF production and what will be the accepted GHG calculation methodologies. Argonne GREET, Corsia approved (RSB and ISCC)?
RH: Up to $1.75, depending on CI score and meeting labor conditions. No guidance from the IRS as yet, but we think it will be the Argonne GREET model as it has to apply to all fuels – we do not know what the audit trail will be.
Renewable Natural Gas (RNG)
When will the production tax credit come accessible for existing RNG projects?
GA: The implementation guidelines are still under development however companies can work with Eco to ensure their clean fuel will meet the LCA requirements through a preliminary CI calculation.
For Dairy Manure to RNG Projects, can the Project receive both the 30% ITC and the 45Z PTC (3 years)?
GA: Under USC § 48(a)(5)(B) “No credit shall be allowed under section 45 for any taxable year with respect to any qualified investment credit facility.”
Can you confirm landfill gas to RNG projects are eligible to either Production Tax Credit or Investment Tax Credit (PTC or ITC)? IRA mentions a methane concentration of 52% that brings confusion, as landfill gas contains usually less than 52% methane.
GA: At this point we are waiting for the implementation guidelines. The 52% minimum requirement applies for the ITC, under USC § 48(c)(7)(B) Inclusion of cleaning and conditioning property The term “qualified biogas property” includes any property which is part of such system which cleans or conditions such gas.” which may be interpreted as the upgrading system to obtain RNG. We expect the boundaries and clear definition of the “system” to be provided in the guidelines. For the PTC, the eligibility factor is the emissions rate that need to not greater than 50kg of CO2e per MMBtu under the Argonne GREET.
How does 45Z apply to RNG?
GA: Implementation guidelines still under development. What IRA includes is a base credit of $0.20/gallon equivalent with an alternative amount of $1/gallon equivalent if the facility satisfies the prevailing wage and apprenticeship requirements. Emissions rate can’t be higher than 50kg of CO2e per MMBtu under the Argonne GREET. It applies to fuel produced after December 31, 2024 and before December 31, 2027.
What are the teams’ views on 45Z and manure-based RNG? Do you think the version of the GREET model will include avoided methane giving access to greater than $1 per GGE assuming the project meets the prevailing wage and apprenticeship requirements?
GA: We need to wait for the guidelines; it’s unknown at this time.
Other Topics
Canada is close to releasing their own set of incentives in response to the IRA. Any expectations for what this could look like?
MP: Canada recognizes that the IRA is extremely appealing and Canada must continue to create an equal appealing policy. Canada stated it has to do more over and above what they currently have in place to continue to build a clean energy economy. But nothing concrete on what it will look like. EcoEngineers anticipates it will be on par with the IRA but aligned with Canada’s goals for a clean economy. Here’s a video from Finance Minister Freeland addressing the IRA.
These credits are based on tax liability. How do you see a potential new credit market(s) forming for every type of entity to be able to capitalize on these credits.
RH: If it follows the BTC model, these credits will be paid directly in dollars to the facility. They are not carbon credits.
You said these new statutes are only in place for 3 years. Can you please expand on that? I was under the impression these were good through 2030-something.
Daniel Ciarcia: This varies by the specific benefit. 45Q (CCS) applies to products that are commenced up to 2033. But, 45Z (Clean Fuel Production Credit) and 45V, 48PTC, 48ITC (Production and Investment Tax Credits) are eligible for projects built between 2024-2027.
We hope you enjoyed both the webinar and the extra information provided in this follow up. For more information about EcoEngineers’ role in helping interested parties participate in the IRA, contact us at clientservices@ecoengineers.us.
Transitioning to a sustainable and equitable world is one of the greatest challenges humankind has faced. It’s the balance of maintaining and raising human standard of living for all, while reducing waste, loss of biodiversity, and carbon emissions – sustainable development. This requires a complete transformation of how we produce, store, and use energy.
Low carbon fuels, particularly clean hydrogen, will play an important role in the energy transition. And to make real progress, we need to understand the environmental aspects and potential impacts of producing, transporting, and using clean hydrogen. To asses these impacts, we use a technique called Life-Cycle Analysis (LCA).
Conducting an LCA involves compiling an inventory of relevant energy and material inputs and environmental releases; evaluating the potential environmental impacts associated with the identified inputs and releases; and then interpreting the results to help you make more informed decisions. This expertise of multi-disciplinary teams is often not available in-house. What’s your clean hydrogen project’s CI score?
A carbon intensity (CI) score is the aggregated greenhouse gas (GHG) emissions during the “life cycle” of a fuel divided by the quantity of the fuel. To qualify for the clean hydrogen production tax credit (45v) under the United States Inflation Reduction Act (IRA) of 2022, you’ll need an LCA to determine if the hydrogen has a CI score of 4 kg CO2e per kg of hydrogen or lower on a well-to-gate basis. An LCA should be conducted as early as possible in the project development cycle. You’ll want to design your project from the outset to maximize the value of the 45v tax credit and other relevant programs. EcoEngineers helps companies develop clean fuels projects from conception to commissioning, including the review of off-take agreements. After the project is up and running, we provide ongoing compliance management to make sure your revenue stream from carbon credits and incentives remains stable.
Our services include:
Life-Cycle Analysis
LCFS Pathway Application
Investment Due Diligence
Feasibility Studies
Offtake Market & Revenue Analysis
H2 Project Development
White Papers
Training & Education
Regulatory Engagement
Ongoing Compliance Management
EcoEngineers has performed more than 500 carbon LCAs since 2015. We have experience in all of the regulations that require LCA, including the US Renewable Fuel Standard (RFS), California Low Carbon Fuel Standard (LCFS), Oregon Clean Fuels Program (CFP), Canada Clean Fuel Regulations (CFR), British Columbia Renewable and Low Carbon Fuel Requirements (RLCFR), Brazil RenovaBio, EU Renewable Energy Directive (RED) and impending directives, along with emerging Voluntary Carbon Markets.
We are your trusted guide to navigating the ever-changing energy landscape ahead.
EcoEngineers helps organizations create sustainable solutions for a better tomorrow. Our team of engineers, scientists, auditors, consultants, researchers, and analysts live and work at the intersection of low-carbon fuel policy, innovative technologies, and the carbon marketplace.
Our core services are the building blocks of a clean energy economy. We provide the right tools, guidance, and knowledge to reduce your carbon footprint and by doing so, mitigating the risks to your business from the uncertainties caused by a changing climate and low-carbon policies. Through our systematic approach, we deliver value and proven expertise through the entire clean energy continuum.
Tanya PeacockGuillermo Aguirre
For more information about our clean hydrogen services, contact: Tanya Peacock, Managing Director California | tpeacock@ecoengineers.us Guillermo Aguirre, Carbon Consultant | gaguirre@ecoengineers.us
When EcoEngineers was formed in 2009, one of the first services we offered was a system to track Renewable Identification Numbers (RINs), called the RIN Management System (RMS). We recognized that producers of renewable fuels would need a way to track their RIN and fuel transactions easily, and we developed the RMS to meet that need.
Tailored for small to mid-sized companies who don’t have capacity to manage RIN transactions, RMS is a secure, cloud-based subscription service that helps producers and marketers track all buy, sell, and trade activity for RIN credits and fuel transactions. It interfaces with the US Environmental Protection Agency Moderated Transaction System (EMTS) and keeps all transactions related to RIN credits in one place. Because it’s cloud-based, you can log in and complete your work from anywhere, securely.
There are several benefits to having a RIN Management service, including:
Organized, User-Friendly System: The dashboard view provides an overview of transactions that may need your attention, allowing users to quickly confirm buys and check any pending sales. Relevant updates and notices are posted on the dashboard, and users can easily move through the platform using the navigation toolbar.
Multiple Transactions: RMS helps producers save time and provides plenty of flexibility. It allows you to complete multiple transactions with a single entry, and there are several options available.
Pending Sell Data: The Pending Sell page shows any “sell” transactions that have not been accepted by the buyer, and the number of days until the sell expires in EMTS. RMS automatically resubmits the sell until it is accepted by the buyer or becomes too old.
Compliant: USEPA requires certain information for each RIN transactions, including fuel pathway, volume, quantity and QAP type. They also require a Product Transfer Document (PTD) with each transaction. Our RMS ensures your transactions are all USEPA-compliant. PTDs are stored and easily retrieved in the system.
Reporting: Solid reporting provides a system of record for compliance purposes. Our reporting shows your RIN inventory at a glance. Transaction reports can be quickly downloaded as needed. Quarterly reports can be used to aid in quarterly and annual fuel pathway reporting.
Secure Data Warehouse: RMS is Sarbanes-Oxley Act (SOX)-compliant – which is a requirement for publicly-traded companies – and is hosted on Amazon Web Services (AWS), one of the most flexible and secure cloud computing environments available.
Help Desk/Regulatory Expertise: Our RMS team provides onboarding and training, and with their background in RFS, they can provide regulatory guidance to ensure you’re correctly submitting your RIN and fuel transactions.
Whether you’re a new fuel producer, or you’ve been in the market for years, consider using EcoEngineers’ RMS to manage your RIN program. It’s perfect for small to mid-sized companies who don’t have capacity to manage RIN transactions.
Transitioning to a sustainable and equitable world is one of the greatest challenges humankind has faced. It’s the balance of maintaining and raising human standard of living for all, while reducing waste, loss of biodiversity, and carbon emissions – sustainable development. This requires a complete transformation of how we produce, store, and use energy.
Carbon markets play an important role. While some companies are required by state or federal regulations to manage their carbon footprints, there is a growing imperative among individuals, municipalities, and corporations to be carbon neutral or to monetize their carbon through voluntary carbon markets.
This exponentially growing world of voluntary carbon markets requires an understanding of carbon accounting, project finance, emission reduction forecasting, monitoring, reporting, verification, and the drivers for the ultimate retirement of credits. This expertise of multi-disciplinary teams is often not available in-house.
EcoEngineers helps companies navigate the quickly evolving carbon economy. Our goal is to propel organizations towards decarbonization by simplifying the market access process for projects that improve our climate.
Our team identifies, assesses, and develops projects in the voluntary and compliance carbon markets. We have experience across multiple industries – from innovative, international start-ups creating carbon-removal projects, to large-scale global energy companies developing projects to mitigate their carbon footprint or generate new streams of revenue.
We carefully evaluate all projects to ensure they meet industry standards and establish pathways to voluntary markets. Using a creative and unbiased approach, EcoEngineers determines a project’s viability and develops cutting-edge methodologies to ensure it benefits the environment.
Our comprehensive socio-environmental assessments help you meet the highest environmental, social, and governance (ESG) standards, with complete Life-cycle Analysis (LCA); verification and validation of low carbon fuel purchases; greenhouse gas (GHG) emissions inventories; carbon offset project claims; measurement, reporting, and verification (MRV) protocols; audits; and carbon registry requirements.
We are the incubator for climate action.
EcoEngineers is working with some of the industry’s leading companies on innovative project around the world to reduce emission, remove carbon and avoid carbon in a plethora of diverse areas. Sample projects include:
Bioenergy Carbon Capture and Sequestration (BECCS):
Ethanol
Woody biomass at pellet plant (sawmills, timber operations)
EcoEngineers is partnering with Patch, a climate action technology platform to ensure the integrity of new carbon removal techniques introduced into the carbon marketplace. Link here to learn more.
For more information about our voluntary market services, contact:
Transitioning to a low-carbon economy is creating new challenges and enormous opportunities for businesses. Emerging climate regulations and carbon markets, along with subsidies and tax credits that assist decarbonization, are creating enormous opportunities for businesses. The key to success is understanding the language of carbon accounting and carbon markets.
This is where Carbon Literacy comes in. EcoEngineers has created a comprehensive Carbon Literacy training program to help you understand and adapt to evolving climate change issues and develop strategies to navigate and benefit from this disruption.
EcoEngineers’ Carbon Literacy training is designed to bring together internal stakeholders, from the CEO, CFO and Chief Sustainability Officer to operations managers and frontline staff, to develop a shared vocabulary and speak the same language related to the energy transition.
Our program is modular and customizable and will help prepare you and your team to discuss climate change science, measure climate risk, develop adaptation and mitigation strategies, and participate in carbon markets in the context of your business.
To learn how your organization can benefit from this training, contact EcoUniversity Director Lyndsey Nielsen at lnielsen@ecoengineers.us.
On Nov. 9, 2022, the California Air Resources Board (CARB) held a public workshop discussing the need for changes to the California Low Carbon Fuel Standard (LCFS) and introducing initial modeling scenarios aimed at further greenhouse gas reductions by 2030 and 2045.
EcoEngineers President Brad Pleima, P.E., summarizes the workshop announcements in the video above. He emphasizes how the rulings might affect low-carbon fuel producers participating or planning to participate in the LCFS.
CARB is soliciting feedback on its proposed alternatives. Written comments will be accepted on their website, and all feedback must be submitted by Dec. 9, 2022.
If you would like to submit feedback to CARB, EcoEngineers’ Regulatory Engagement Team can assist in these efforts. To learn more, contact us at clientservices@ecoengineers.us.
Its fall season, soup season, and (most importantly) football season! Who doesn’t love football? I thought it would be interesting to see what the National Football League is doing to be more sustainable.
From the NFL: “NFL Green, the league’s environmental program, works to mitigate the environmental impact of the NFL’s major events and create a “green” legacy in each community that hosts Super Bowl, Pro Bowl, and the NFL Draft. These objectives are addressed through active partnerships with NFL sponsors, local host committees, government agencies, and nonprofit organizations.” Below are ways the NFL is becoming more sustainable.
Food Recovery
The Super Bowl can generate 140,000 pounds of excess food and beverages. The NFL works with local foodbanks to ensure the leftover food and drink is donated.
Material Recovery
Think about how much material is used when having the Super Bowl. Carpet, signs, décor, building materials, etc., all of this material that can be collected and reused is given to various nonprofit groups like Habitat for Humanity, Salvation Army, etc.
Recycling and Solid Waste Management
The community will develop initiatives to keep waste out of landfills from the increased waste generated.
Super Bowl E-Waste Event
“Each year, a one-day public E-Waste event is hosted in partnership with the local zoo just before the Super Bowl,” the website says. People in the community can bring e-waste to a drop off, where it is responsibly recycled.
Green Energy
Renewable energy certificates will be purchased to offset the energy usage during the Super Bowl.
Chelsa Anderson is a Carbon Consultant for EcoEngineers. She has an eye for innovative sustainability projects. Have you seen relevant or innovative news or articles surrounding the Clean Energy Economy? If so, shoot her an email at canderson@ecoengineers.us, and she can feature it in the next update. Articles should be evergreen in nature and not specifically tied to a particular publication date.
