Insights Archives - EcoEngineers

LaGreca on Red Trail Energy, the First Ethanol Plant to Enter Voluntary Carbon Markets

This podcast was first published by The Crude Life on June 28, 2024.

David LaGreca, Managing Director of Voluntary Carbon Markets Services, EcoEngineers, joins Jason Spiess and Steve Bakken on Townsquare Media’s SuperTalk 1270 Talk of the Town to share his experience working on the first voluntary carbon sequestration for ethanol in the nation.

Voluntary carbon sequestration involves the capture and storage of carbon dioxide (CO₂) through various projects funded by private entities. This process aims to offset emissions by removing CO2 from the atmosphere or preventing its release. These projects often include reforestation, afforestation, and soil carbon enhancement, among others.

Key Aspects of Voluntary Carbon Sequestration:

Market Dynamics: Voluntary carbon markets allow businesses and individuals to purchase carbon credits to offset their emissions. These credits finance projects that sequester carbon, contributing to overall climate goals.
Verification and Standards: Projects in voluntary carbon markets must adhere to stringent verification and monitoring standards to ensure their effectiveness. Organizations like Verra and the ICVCM set these standards, ensuring that carbon credits represent real and verifiable climate benefits.
Global Initiatives: Various global initiatives and evolving models are enhancing the structure and credibility of voluntary carbon markets, making them more robust and effective in addressing climate change.
Economic Incentives: Voluntary carbon credits direct private financing to climate-action projects, enabling initiatives that might not receive funding otherwise. This can stimulate economic growth while promoting environmental sustainability

The Red Trail Energy (RTE) Carbon Capture and Storage (CCS) project represents a significant milestone in the integration of carbon capture technology within the ethanol production industry.

Located near Richardton, North Dakota, this project is a pioneering effort to reduce carbon dioxide (CO₂) emissions from ethanol production, making it more sustainable and competitive in markets with stringent low-carbon fuel standards.

Project Overview

The RTE CCS project officially commenced operations in July 2022. This project involves capturing CO₂ emissions from the ethanol production process and securely storing them underground. This initiative aims to capture more than 90% of the CO2 emissions produced by the ethanol facility, significantly reducing its carbon footprint.

Technology Used

The CCS technology employed by RTE includes several advanced components:

Capture: CO₂ is captured from the fermentation process during ethanol production. This step involves separating CO2 from other gases using amine-based solvents.
Compression: The captured CO₂ is compressed to a supercritical state to facilitate transport and injection.
Transportation: The supercritical CO₂ is transported via pipelines to the injection site.
Injection and Storage: The CO₂ is injected into deep geological formations, such as saline aquifers, where it is securely stored and prevented from entering the atmosphere.

Environmental and Economic Benefits

Implementing CCS at RTE’s ethanol plant brings both environmental and economic benefits. By significantly reducing CO₂ emissions, the project helps mitigate climate change impacts.

Additionally, it enhances the competitiveness of RTE’s ethanol in markets with low-carbon fuel programs, potentially leading to economic incentives and regulatory advantages.

Milestones and Statistics

Start of Operations: The project began capturing and storing CO₂ in July 2022.
Capture Efficiency: The technology can capture over 90% of the CO₂ emissions from the ethanol production process.
Emissions Reduction: The project aims to reduce the net CO₂ emissions of the ethanol plant, contributing significantly to the overall goal of lowering the carbon intensity of ethanol fuel.

Conclusion

The Red Trail Energy CCS project is a landmark development in the ethanol industry, showcasing how advanced carbon capture technology can be effectively integrated to reduce greenhouse gas emissions.

This project not only positions RTE as a leader in sustainable ethanol production but also sets a precedent for other industrial facilities aiming to lower their carbon footprints.

To contact LaGreca, click here for his LinkedIn Profile or Company Website.

FEW Podcast Series: Live with EcoEngineers

This podcast was first published by Ethanol Producer Magazine on July 10, 2024.

S3 E15 Produced by Ethanol Producer Magazine, EcoEngineers’ Vice President of U.S. Biofuels, Jim Ramm, chats about what’s new with EcoEngineers.

Recorded live at the 2024 Int’l Fuel Ethanol Workshop & Expo in Minneapolis, Minnesota.

Hosted by Anna Simet, Associate Editor

Sponsored by EcoEngineers Visit EthanolProducer.com for additional industry news.

For More EPM Podcasts visit: • EPM’s Podcast Series

Qualifying for Tax Credits Under Section 45V

To qualify for the tax credit under the U.S. Inflation Reduction Act (IRA), Section 45V(c)(2)(B)(ii) specifies that the production and sale or use of clean hydrogen must be confirmed by a qualified verifier. EcoEngineers (Eco) is an experienced auditor and qualified verifier as defined in the proposed Section 45V regulations, published on December 26, 2023, in the Federal Register.

Eco applies a meticulous and comprehensive approach to auditing and verifying the reported data and associated data controls put in place by clean hydrogen production facilities. We develop an initial audit plan based on the requirements for verification reports in the proposed regulations of §1.45V-5, “Procedures for verification of qualified clean hydrogen production and sale or use.” The draft regulations state that taxpayers may rely on these proposed regulations for taxable years beginning after December 31, 2022, and before the date the final regulations are published in the Federal Register, provided the taxpayer follows the proposed regulations in their entirety and a consistent manner. Eco’s audit plan for each client will be updated as necessary to reflect requirements in the final regulations when issued.

Eco conducts IRA Section 45V verifications in accordance with the International Organization for Standardization (ISO) 14064:3:2019. Our verification approach is as follows:

EcoEngineers is accredited by ANSI National Accreditation Board (ANAB) as a greenhouse gas (GHG) verification body in accordance with ISO standards ISO/IEC 17029:2019, ISO 14065:2020, and ISO 14064-3:2019.

For more information, please contact: Tanya Peacock, Managing Director, California and Hydrogen | tpeacock@ecoengineers.us

About EcoEngineers

Eco is a consulting, auditing, 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 in 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.

National Petroleum Council Report Highlights Hydrogen’s Critical Role

By Tanya Peacock, EcoEngineers

As part of a diverse group of experts who participated in the study that provided the data for the National Petroleum Council (NPC) hydrogen report, I’ve gained a few insights and opinions on the report’s findings and what will be required to ensure clean hydrogen emerges as a promising pathway toward decarbonization.

Clean hydrogen emerges as a key player among the myriad technologies vying for attention in the quest to achieve net-zero emissions by 2050. However, the clean hydrogen industry will need additional economic and policy incentives if it is to grow supply and demand to help reach this goal, according to the NPC report, titled “Harnessing Hydrogen: A Key Element of the U.S. Energy Future.”

The NPC assembled a team of more than 200 experts from more than 100 organizations, 70% of whom come from outside of the oil and gas industry, including myself. The study was conducted in partnership with the Massachusetts Institute of Technology (MIT) Energy Initiative and leveraged scenario-based modeling. The study generated unique insights due to the diverse perspectives of the study participants, many of whom, like me, have practical experience with clean energy project development.

Report’s Top Findings

The NPC report includes 19 findings and 23 recommendations that, if acted upon, would help drive the deployment of low carbon intensity (LCI) hydrogen at scale through the entire value chain, including production, storage, liquefaction, transportation, and end uses. The top finding is the need for an economy-wide explicit price on carbon.

The second and third findings are a national low-carbon-intensity industry standard and a national low-carbon-intensity transportation standard. The diversity of organizations – from oil and gas to environmental non-profits – that came together to agree on these recommendations for putting a price on embedded carbon was both surprising and inspiring, and a marked difference from the Low Carbon Fuel Standard (LCFS) implementation process in the late 2000s and early 2010s. “Harnessing Hydrogen” shows our evolving understanding of the need for market-based programs to support carbon reductions and economic prosperity in a carbon-constrained world.

Increased Policy Support Needed to Scale Clean Hydrogen

Central to the NPC report’s findings is how important it is to secure additional federal support to reach levels required to achieve net-zero U.S. carbon emissions by 2050. Current federal policies, including the IRA Section 45V clean hydrogen tax credit under the Inflation Reduction Act (IRA) and hydrogen hubs funded by the 2021 Bipartisan Infrastructure Law, would roughly double annual hydrogen production and demand by 2050 from about 11 million metric tonnes per year in 2021, according to the NPC report.

–National Petroleum Council, “Harnessing Hydrogen: A Key Element of the U.S. Energy Future”

While the NPC report finds that low-carbon intensity (LCI) hydrogen could abate about 8% of U.S. carbon emissions by 2050 at a lower cost than non-hydrogen alternatives, it’s obvious that significant and immediate actions beyond current policies are needed. To achieve this goal, clean hydrogen demand would need to increase sevenfold from 2021 levels to 75 million metric tons per year to enable a cost-effective path to net zero in the U.S. by 2050.

To spur production-side incentives of LCI hydrogen, the NPC recommends Congress adjust the IRA Section 45V clean hydrogen tax credits by extending the credit-claiming period to 20 years to match the incentive more closely with asset life cycles and advocates for greater utilization of Greenhouse Gases, Regulated Emissions, and Energy Use in Technologies (GREET) model capabilities, including co-product allocation and the use of verifiable values for life-cycle analysis (LCA). The NPC, however, did not weigh in on IRA Section 45V’s contentious method to account for the emissions of hydrogen made from grid electricity.

Shrinking the Cost Gap of Clean Hydrogen

To reach net-zero carbon emissions by 2050, delivering LCI hydrogen at scale will require an evolving split between hydrogen from two key production pathways: fossil natural gas reformed hydrogen—or “blue” hydrogen—with carbon capture and storage (CCS) and renewable electrolytic hydrogen—or “green” hydrogen.

A cumulative capital investment of US$1.8 trillion will be needed to scale green hydrogen between now and 2050. To put this into perspective, green hydrogen production would require installed electrolyzer capacity to grow at a compound annual growth rate of 27% over the next 25 years.

–National Petroleum Council, “Harnessing Hydrogen: A Key Element of the U.S. Energy Future”

“While the required investment and growth rate to reach net zero supported by LCI hydrogen is formidable, it is comparable to the North American capital investment in upstream oil and gas ($1.9 trillion) and solar installation (30% compound annual growth rate) in the last decade,” states the NPC report.

Meanwhile, blue hydrogen coupled with carbon capture will require $100 billion in investments between now and 2050 to accomplish the same.

LCI hydrogen production will initially be driven by natural gas with CCS due to lower-cost feedstock availability and the ability to rapidly scale production, according to the NPC report, as it can provide the initial large-scale production needed to support dependable LCI hydrogen supply to new and existing end users, thus helping establish the LCI hydrogen economy.

To achieve net zero by 2050, the CI of the LCI hydrogen production mix will need to experience continued reductions over time. “As the U.S. economy moves toward net zero, the marginal cost of abatement will rise,” according to the NPC report. “Ultimately, the production mix in the [net-zero 2050] scenario will have a higher proportion of [green hydrogen] due to its lower carbon emissions, the projected higher future cost of carbon, and anticipated cost reductions for green hydrogen.”

–National Petroleum Council, “Harnessing Hydrogen: A Key Element of the U.S. Energy Future”

In summary, the NPC report underscores the necessity for substantial policy interventions and investment to scale LCI hydrogen and achieve net-zero carbon emissions by 2050. Stakeholders across a multitude of industries must collaborate to implement the report’s recommendations, such as adjusting the IRA Section 45V clean hydrogen tax credit and increasing federal support for LCI hydrogen production technologies. Now is the time for decisive action to build a robust clean hydrogen economy that can meet our ambitious climate goals.

For more information on the NPC’s findings in the report or Eco’s hydrogen services, please contact:

Tanya Peacock, Managing Director, California and Hydrogen | tpeacock@ecoengineers.us

Top Five Reasons to Attend the EcoEngineers LCA Academy

As climate regulations and tax credits evolve, consumer preferences shift, and opportunities in voluntary carbon markets (VCMs) emerge, life-cycle analyses (LCAs) have become the cornerstone of these developments. Understanding and implementing LCAs is crucial for businesses to stay ahead in these changing times.

To offer businesses a unique opportunity to gain expertise in this area, EcoEngineers is excited to announce our Life-Cycle Analysis Academy, a 1.5 day program being held in Des Moines, June 25-26, and in Houston, September 4-5.

Here are the top five reasons why you should attend the LCA Academy:

Immersive Learning Experience
An LCA is a systematic and comprehensive method for evaluating and quantifying the environmental impact of a product, service, or system from its inception to its end-of-life. The LCA Academy provides a thorough understanding of the foundations of LCA concepts, methodologies, and their role in environmental, social, and governance (ESG) compliance. You will learn how to evaluate the environmental impact of products from inception to end-of-life, covering various impact categories such as carbon footprint, land use, water use, and more.
Expert Insights and Networking
Eco’s team of renowned scientists and industry experts have performed more than 1,000 carbon LCAs since 2015. Attendees will benefit from our vast experience and insights, learning from leaders in the ever-changing carbon marketplace. For example, we used LCAs to help Red Trail Energy (RTE) achieve business continuity and optionality to become the first ethanol producer to enter the VCM and the largest carbon removal project registered to date. The event also provides networking opportunities with other professionals and influencers, facilitating knowledge exchange, collaboration, and building valuable connections in the LCA and sustainability community.
Influence Industry Trends and Policies
The Executive Track offers a roundtable discussion focused on developing a consistent LCA approach in policies. Participants can contribute to the future direction of industry standards and regulations. Confirmed presenters include:

- Brent Heard, Senior Program Officer, National Academies of Sciences, Engineering, and Medicine (NASEM)
- Ben Hengst, Deputy Director, Office of Transportation and Air Quality, U.S. Environmental Protection Agency (USEPA)
- Chris Ramig, Environmental Policy Analyst, Office of Transportation and Air Quality, U.S. Environmental Protection Agency (USEPA)
- Zia Haq, Senior Lead Analyst, Data, Modeling, and Analysis, Department of Energy (DOE) Bioenergy Technologies Office (BETO)

Hands-On Training
The Practitioner Track offers immersive workshops that provide hands-on experience with leading LCA technologies and ISO standards that are crucial for measuring accurate environmental impact assessments. You’ll learn to model carbon intensity (CI) scores, analyze results, and create an LCA model from scratch. This practical experience is invaluable for understanding the complexities of LCAs and effectively applying them in real-world scenarios.
Stay Ahead in a Changing Market
As climate regulations continually evolve, understanding and implementing LCAs is crucial for organizations to meet regulations, realize tax incentives, and enter into voluntary carbon markets. For example, following the passage of the Inflation Reduction Act (IRA), the Internal Revenue Service (IRS) recently announced that starting in 2025, biofuel tax credit applicants under IRA Section 45Z will be required to perform an LCA to determine the amount of credit they can receive. Further guidance from the IRS declared a 10-point reduction in a farm’s carbon footprint if it adopted certain regenerative farming practices such as cover cropping, no-till management, or nitrogen management.

Whether you are an executive looking to shape policies or a practitioner seeking hands-on experience, the LCA Academy is a valuable investment in your professional development and environmental impact.

For more details and to register for Eco’s LCA Academy, CLICK HERE.

To learn more about Eco’s LCA expertise and capabilities, CLICK HERE.

Prepare for CBAM Compliance

The following is an article originally published May 24, 2024, by Steel Times International.

Prepare for CBAM Compliance

The European Union’s (EU) Clean Border Adjustment Mechanism (CBAM) is a landmark regulatory framework aimed at curbing emissions embedded in imported goods, including steel. By 2026, it will require steel importers to fully measure, report, and pay for these greenhouse gas (GHG) emissions, aligning imported goods with the stringency of the EU’s climate policies.

By Urszula Szalkowska

In anticipation of CBAM’s full implementation, the first reporting phase has already commenced, with a grace period allowing the use of default emission values until June 2024. Nevertheless, steel producers are urged to prepare for more rigorous emissions reporting in compliance with EU methodology to maintain competitiveness in the EU market. From 2026 onward, importers must procure CBAM certificates at prices reflecting the EU Emissions Trading System (ETS), further incentivizing accurate emissions declarations.

Non-EU Importers Held to Standard

CBAM’s inception is a strategic move to address carbon emissions by ensuring that non-EU manufacturers are held to similar GHG-reduction standards as those within the EU. It attempts to level the playing field between domestic and foreign producers and reinforces the EU’s commitment to becoming a carbon-neutral continent by 2050. This mechanism marks a shift from negotiated international environmental regulations towards the EU leveraging its market power to project its climate policies globally. As such, it signifies the maturing and globalization of carbon markets, requiring producers worldwide to adapt to these comprehensive standards.

Prepare Now for EU Methodology

Currently, importers can use the EU calculation methodology or emissions calculations accepted in countries of origin or default values listed by the European Commission to report embedded emissions. Based on CBAM reports received in January 2024, most importers used the last easiest option, i.e., default values. However, as mentioned previously, this type of reporting will no longer be accepted after June 2024.

After a transition period in 2025, the EU calculation methodology and its emissions factors will be required for CBAM reporting in 2026. This means that importers and producers should be already preparing for actual life cycle GHG emissions reporting following the EU methodology to remain competitive in the European market.

Additionally, importers in 2026 will be required to purchase CBAM certificates corresponding to the declared emissions. The price of CBAM certificates will be based on the weekly average price of the EU ETS allowance and expressed in EUR/tonne of CO₂ emitted. An independent accredited verifier will need to verify the declaration’s accuracy. Each year, by 31 May, starting in 2026, declarants will surrender CBAM certificates equivalent to their declared and verified embedded emissions. CBAM certificates will not be tradable, but they can be re-purchased by a regulator that issued them.

New importers of iron and steel can register at any time they decide to bring goods covered by CBAM to the EU market. Depending on when they become importers, they need to follow the rules applicable in this specific period. For example, until the end of 2025, they need to follow transitional rules; starting in 2026, they must follow full compliance rules.

Importers can claim emissions reductions if a carbon price was paid in the country of origin and deduct this price from the CBAM cost. Details on how the EU will incorporate foreign climate policies into CBAM calculations will be finalized before a definitive rule is entered into force. The European Commission claims that it will consider the position of its international partners. In the meantime, some countries are already deliberating how to accommodate CBAM. For example, China is contemplating including CBAM sectors in its own cap-and-trade scheme, and India is discussing a CO₂ tax.

As the CBAM enters into force, foreign companies must navigate the complexity of the system and its timeline to ensure compliance. Understanding these key requirements and the depth of the regulation is crucial for exporters looking to participate in the European markets.

For more information:

For more information about CBAM or other EU climate policies and programs, please contact Urszula Szalkowska at uszalkowska@ecoengineers.us.

Urszula Szalkowska is based in Poland and is the managing director, Europe for EcoEngineers.

U.S. Treasury, IRS Release Additional Guidance on Section 40B Sustainable Aviation Fuel (SAF) Credits and Modified GREET Modeling

On April 30, 2024, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) published a third piece of guidance regarding the sustainable aviation fuel (SAF) credits implemented under Section 40B of the Inflation Reduction Act of 2022 (IRA) and 6426(k) of the Internal Revenue Code (IRC). The following information contains highlights of this notice. Producers will find guidance concerning SAF credits, life-cycle analysis, verification requirements, and emissions reductions safe harbor.

Highlights

The IRS/Treasury guidance also announced the release of the new 40BSAF-GREET 2024 model to be used in calculating greenhouse gas (GHG) emissions for the hydroprocessed esters and fatty acids (HEFA production pathway) and alcohol-to-jet (ATJ-ethanol pathway).
An additional emissions reduction opportunity is included when using corn or soybeans as part of the U.S. Department of Agriculture (USDA) Climate Smart Agriculture Pilot Program (USDA CSA Pilot Program).
The modified GREET will only apply to the Section 40B SAF blending credit, which expires at the end of 2024.
Use of the modified GREET model for Section 40B will require third-party certification and compliance.
Renewable energy certificates (RECs) will be eligible, as well as credits for carbon capture and sequestration (CCS).

Full Summary

The U.S. Treasury Department and IRS notice issued on April 30, 2024, regarding the SAF credits implemented under Section 40B and 6426(k) of the Internal Revenue Code (IRC) includes the release of the new 40BSAF-GREET 2024 model to be used in calculating greenhouse gas (GHG) emissions, as well as an additional emissions reduction opportunity when using corn or soybeans as part of the U.S. Department of Agriculture (USDA) Climate Smart Agriculture Pilot Program (USDA CSA Pilot Program).

The modified GREET will only apply to the Section 40B SAF blending credit, which expires at the end of 2024. It is uncertain whether this model will remain the same or be updated for use with the Section 45Z tax credit, which goes into effect starting January 1, 2025, until the end of 2027.

The new 40BSAF-GREET 2024 model calculates emissions from two production pathways: hydroprocessed esters and fatty acids (HEFA production pathway) and alcohol-to-jet (ATJ-ethanol pathway). Per the regulation in IRC Section 40B, the use of the model will require third-party certification of compliance. Certification from a California Low Carbon Fuel Standard (CA-LCFS) verifier will be considered as meeting requirements if the certification is obtained in a form similar to an LCFS Verification Statement. If the producer uses CSA feedstock (described below), a different certification format will be used. EcoEngineers’ expert Life Cycle Analysis (LCA) team is doing a deep dive into the new 40BSAF-GREET 2024 model. Upon the first review of the User Manual, it appears renewable energy certificates (RECs) will be eligible, as well as credits for carbon capture and sequestration (CCS).

Corn used in an ATJ-ethanol pathway that is part of the USDA CSA Pilot Program is eligible for a 10-point reduction in the life-cycle emissions value, while soybeans used in the HEFA pathway are eligible for a five-point reduction. For corn production to qualify under CSA, the farm must use the practices of no-till, enhanced low-carbon fertilizer, and cover crops. CSA soybean producers must only use no-till farming and plant cover crops. The entire field must be subject to these practices and the feedstock must be grown in the United States (U.S.). Farmers must obtain a Certificate for Climate Smart Agriculture Crops.

SAF producers using CSA feedstock must have a direct contract with a farmer, collect and maintain the Certificate for Climate Smart Agriculture Crops from the farmer, maintain records as described in Appendix A of the notice, and allow all records to be available for certification. Certification requires the auditing of supply chain records and a complete mass balance sheet verifying the traceability of crops to the SAF producer.

Applicants with pending applications for the credit who would like to instead claim credits using the new methodology may contact the IRS to do so.

A link to the notice can be found here.

Our team is ready to assist you with addressing your regulatory, LCA, and/or auditing/verification needs, and to be a resource for you in answering questions to successfully comply and monetize credits under this new guidance.

For more information about our regulatory, LCA, or auditing/verification services as they pertain to the latest IRS and U.S. Treasury Section 40B SAF guidance, please contact clientservices@ecoengineers.us.

Summary of California Low Carbon Fuel Standard Workshop – April 2024

The California Air Resources Board (CARB) held a workshop on April 10, 2024, addressing the proposed regulatory amendments to the California Low Carbon Fuel Standard (LCFS) program. This workshop discussed potential revisions to the rule, as well as sought additional feedback and comments from stakeholders. EcoEngineers is providing the following summary to highlight potential changes and areas of re-evaluation from the initial proposal.

A link to the presentation and supplemental documentation referred to can be found at: LCFS Meetings and Workshops | California Air Resources Board.

For more information, please contact Lisa Hanke at lhanke@ecoengineers.us.

Updated Modeling

CARB proposed four new step-down scenarios under consideration for the final rule. In creation of the new scenarios, CARB has updated the modeling to reflect:

Increased tailpipe emissions factors for methane (CH₄) and nitrous oxide (N₂O) affecting renewable diesel, biodiesel, and ultra-low sulfur diesel (ULSD);
Increased supply assumptions for renewable diesel from virgin oils and waste oils;
Energy demand from plug-in hybrid electric vehicles (PHEVs) and medium-duty vehicles (MDVs).

The first three of the new scenarios being analyzed reflect step-downs at 5%, 7%, and 9%. All three of the scenarios result in a 30% carbon intensity (CI) reduction by 2030 and a 90% CI reduction by 2045. The fourth scenario being analyzed is a 5% step-down in 2025 with the auto-acceleration mechanism triggered twice. This results in a 39% CI reduction by 2030 and 90% CI reduction in 2043. EcoEngineers had recommended a steeper step-down rate in the company’s written comments to CARB, and several commenters in attendance also supported a steeper step-down, many with preference for 9%.

The following chart from compares the modeled scenarios:

Source: CARB, LCFS Workshop Slide #47

Feedback was requested from CARB to determine the appropriate scenario to implement. Specific feedback requested is shown in the following:

Source: CARB, LCFS Workshop Slide #49

Sustainability Criteria

In addition to the originally proposed regulation, CARB is evaluating an increase in LUC values for high-risk feedstocks and methods to increase traceability, verification, and/or enforcement of waste feedstock. LUC changes may be based on empirical sub-national data, such as remote sensing or satellite monitoring. CARB requested feedback for potential data sources.

Additionally, CARB indicated several times throughout the workshop that they are interested in obtaining feedback for how the proposed sustainability certification should be implemented. Originally proposed regulations were based on existing certification programs, for example, International Sustainability and Carbon Certification (ISCC).

MDV/HDV Infrastructure

Though not a focus of the staff’s presentation, many commenters spoke with concern for the MDV/HDV infrastructure crediting regulations. Specifically, regulations regarding the number of eligible chargers at a specific site, which must be less than 10 under the current proposal, is too low, and geographic siting is a major hinderance. CARB expressed openness to obtaining feedback and updating the rules.

Timeline

The timeline for the implementation of the LCFS amendments was provided and is demonstrated below.

Source: CARB, LCFS Workshop Slide #67

Three Priority Takeaways from the USEPA’s RFS Set Rule Implementation Webinar – April 2024

The U.S. Environmental Protection Agency (USEPA) hosted a webinar on April 12, 2024, that served to further clarify the Biogas Regulatory Reform Rule (BRRR) provisions of the Renewable Fuel Standard (RFS) program. EcoEngineers submitted many questions on behalf of our clients for this presentation, and a number of employees attended in the live event.

Documentation from the USEPA’s webinar can be found here: USEPA RFS Set Rule Webinars.

Overall, our experts have highlighted three priority takeaways for biogas and renewable natural gas (RNG) producers from the webinar:

The USEPA reinforced the implementation process and timeline for the BRRR over the next six to eight months. The USEPA will work to re-register existing RNG facilities between July and October. All facilities must be compliant with the new rules by January 1, 2025.
Eco believes that most existing facilities will need to submit an Alternative Measurement Protocol (AMP) with their registration. The AMP will demonstrate how the facility is measuring and metering the gas flows to provide the necessary data within the regulation if all meters do not meet the published specifications per 40 CFR 80.155. Facilities should start drafting these plans now to be submitted with their registration packages.
Facilities will need to provide information in their RIN generation protocols outlining data substitution methodologies in the event data is not collected from an out-of-service or failed piece of metering equipment which often occurs at some point in a facility’s operation. Biogas and RNG producers should begin work on these plans and understand how they may affect other programs they participate in like CA-LCFS and others.

EcoEngineers is following these RFS developments throughout the year, and we are here to help you understand the regulations through the education, engagement, and compliance services we offer.

For more information please contact clientservices@ecoengineers.us.

Navigating the European Biomethane Market

The European Commission’s (EC’s) recent implementation of the Union Database (UDB) represents a significant development in facilitating the traceability of renewable fuels in the European Union (EU) Member States (MS). While currently operational for liquid biofuels, the UDB is set to encompass gaseous renewable fuels such as biomethane by November 21, 2024, aligning with the Renewable Energy Directive III (RED). Since the need to satisfy renewable energy quotas drives a large part of the incremental value of these molecules compared to existing fossil fuel products, this change is relevant to all suppliers of biomethane to the EU market, potentially impacting the commercial feasibility of projects currently under development.

Once the UDB opens for gaseous renewable fuels, certification of biomethane from third countries’ grid will only be possible if the foreign grid meets the conditions described in Article 31a of the RED and the implementing regulation. The foreign grid must ensure full traceability of the biomethane injected and withdrawn from the grid in a mass balance system. In particular, information on sustainability and any support provided for the production of a specific consignment of fuel will have to be recorded in the UDB.

Our Services:

Regulatory Engagement
Compliance Management
Emissions Data Collection and Organization
Life-Cycle Analysis (LCA)
Cost-Benefit Analysis
Investment Due Diligence
Independent Third-Party Verification and Validation
GHG Inventory and Accounting
EcoUniversity Training

Based on the RED and EC’s guidelines, the U.S. grid is not compliant with the European definition of interconnected infrastructure and is not considered a single mass balance system and therefore is not part of the UDB system. The limiting factor in the U.S. is the lack of a federal database to track the sustainability, production, transfer of title, and retirement of the environmental attributes of biomethane.

Recent developments around the UDB present serious challenges for the trade of biomethane between the U.S. and the EU and carry significant repercussions that can jeopardize access of the U.S. biomethane to the EU. There are currently several working groups within the U.S. reviewing alternatives to comply with EU regulations. Whether it is amending the U.S. Environmental Protection Agency (USEPA) Moderated Tracking System (EMTS) to track non-transportation biomethane and include the functionality to capture the emission reduction benefits or utilizing the Midwest Renewable Energy Tracking System (M-RETS®), a registry platform that tracks voluntary biomethane in the U.S., many industry participants feel there is a solution to meeting the EU requirements.

EcoEngineers is your strategic partner in navigating this intricate regulatory landscape, advising you on proactive essential measures to access European market. We bring expertise in both the U.S. and EU regulatory and market developments to help U.S. biomethane suppliers streamline compliance efforts and ensure market integration and business growth on both sides of Atlantic. We also developed an in-depth educational program on the EU’s renewable energy and cap-and-trade systems to help our clients position themselves in the expanding European biomethane market and make strategic business decisions.

About EcoEngineers

EcoEngineers is a consulting, auditing, 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 of engineers, scientists, auditors, consultants, and researchers live and work at the intersection of low-carbon fuel policy, innovative technologies, and the carbon marketplace. 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 more information, please contact:

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

Category: Insights

LaGreca on Red Trail Energy, the First Ethanol Plant to Enter Voluntary Carbon Markets

FEW Podcast Series: Live with EcoEngineers

Qualifying for Tax Credits Under Section 45V

Qualifying for Tax Credits Under Section 45V

National Petroleum Council Report Highlights Hydrogen’s Critical Role

National Petroleum Council Report Highlights Hydrogen’s Critical Role

Report’s Top Findings

Increased Policy Support Needed to Scale Clean Hydrogen

Shrinking the Cost Gap of Clean Hydrogen

Top Five Reasons to Attend the EcoEngineers LCA Academy

Top Five Reasons to Attend the EcoEngineers LCA Academy

Prepare for CBAM Compliance

Prepare for CBAM Compliance

U.S. Treasury, IRS Release Additional Guidance on Section 40B Sustainable Aviation Fuel (SAF) Credits and Modified GREET Modeling

U.S. Treasury, IRS Release Additional Guidance on Section 40B Sustainable Aviation Fuel (SAF) Credits and Modified GREET Modeling

Highlights

Full Summary

Summary of California Low Carbon Fuel Standard Workshop – April 2024

Summary of California Low Carbon Fuel Standard Workshop – April 2024

Updated Modeling

Sustainability Criteria

MDV/HDV Infrastructure

Timeline

Three Priority Takeaways from the USEPA’s RFS Set Rule Implementation Webinar – April 2024

Three Priority Takeaways from the USEPA’s RFS Set Rule Implementation Webinar – April 2024

Navigating the European Biomethane Market

Navigating the European Biomethane Market

About the Company

Expertise

EcoInsights