How to Hire, Fire, and Get Maximum Value From Carbon Market Consultants

This podcast was originally published by Ross Kenyon for the “Reversing Climate Change” on June 11, 2026.

David LaGreca shares his expertise from countless carbon projects during his time at EcoEngineers and beyond

Ongoing Diligence: Chasing Offtake In Carbon Removal Today

This article was originally published by Carbon Herald on April 28, 2026. 

By David LaGreca, managing director of Carbon Markets at EcoEngineers

By the time a carbon dioxide removal (CDR) credit reaches the voluntary carbon market (VCM), it has already passed through an increasingly rigorous set of reviews. Beyond questions of technology or permanence, today’s market puts growing emphasis on how assumptions are tested, data is scrutinized, and projects respond to sustained challenges.

This increased scrutiny is often described as a “quality problem.” In reality, it reflects a maturing market. As buyers, investors, registries, and verifiers apply deeper diligence to minimize risks as much as possible (knowing unknowable risks will always arise), the quality of carbon removal is no longer a static label. It becomes an outcome achieved through process.

The result is a VCM that demands more from projects while providing clearer signals about what credible, investable carbon removal looks like.

From Methodologies to Market Scrutiny

A few years ago, having a credible methodology was often enough to move a project forward. Developers focused on demonstrating that approaches such as bioenergy with carbon capture and storage (BECCS), direct air capture (DAC), or soil carbon mineralization could plausibly remove carbon. Registries validated methodologies, verifiers confirmed conformance, and buyers largely accepted those outcomes.

That era has ended.

Since roughly 2022, trust deficits in the VCM have shifted the center of gravity from registries to buyers. Today, a project may clear registry validation and third-party verification and still fail to secure offtake. Buyers now conduct their own diligence processes or contract with a third-party consultant for diligence, often lasting months, re-examining baseline assumptions, modeling choices, monitoring systems, land-use impacts, governance, and political or reputational risk.

The result is a layered diligence environment in which projects must satisfy multiple stakeholders, each with distinct expectations and incentives.

What Robust Diligence Looks Like in Practice

Despite this fragmentation, a clearer diligence pathway is beginning to emerge. While specifics vary by technology and buyer, high-quality CDR projects increasingly follow a common review sequence that extends beyond registry approval.

  1. Scientific and technical feasibility. This forms the foundation. Projects must demonstrate that their underlying science is credible at a relevant scale and supported by peer-reviewed research or pilot data. Early feasibility assessments help identify red flags before they become costly setbacks. This step is exceptionally important for projects deploying any first-of-its-kind technology, chemistry, or process.
  • Methodology alignment. It’s important that project developers understand that standards and methodologies evolve over time, and that they should aim for the highest attainable bar rather than optimizing for the status quo.
  • Baseline integrity. Whether adapting an existing registry methodology or working within a newer carbon removal standard, projects must show that baselines reflect a credible “no-project” scenario and that crediting assumptions are conservative. Inflated baselines remain one of the fastest ways to lose buyer confidence.
  • Project design and documentation. This translates assumptions into formal plans. Clear, internally consistent documentation that covers system boundaries, monitoring plans, and data management supports validation and reduces friction during downstream reviews.
  • Independent validation and verification. Conducted under International Organization for Standardization (ISO)-aligned requirements, these assessments confirm that projects conform to their chosen methodologies and that claimed removals are supported by evidence. At the same time, verification and credit issuance are no longer tightly coupled to immediate purchase in the voluntary carbon market. Recent market data illustrates the shift: Puro.earth reported that suppliers issued about 650,000 CO₂ Removal Certificates (CORCs) in 2025 while only 344,026 were retired, meaning issuance was roughly 1.9 times retirements for the year. This growing gap reflects a market increasingly driven by forward offtake agreements and future supply reservations rather than spot purchases. Verification therefore remains a critical independent checkpoint for credibility, even as issuance itself no longer guarantees immediate buyer activity.
  • Buyer and investor diligence. Buyers frequently revisit earlier assumptions, interrogate monitoring and reporting systems in greater depth, and evaluate risks ranging from permitting to long-term storage integrity. Projects that have prepared for this scrutiny upstream tend to move through it more efficiently. In other words, project developers should seek out additional scrutiny at the design phase, prior to kicking off the formal registration process with registries.
  • Ongoing monitoring and re-verification. Diligence does not end at first issuance; it must continue over time. Annual or periodic verification and responsiveness to evolving expectations have become defining features of durable projects.

The Stabilizing Role of Verification

One paradox of today’s market is that third-party verification, the only step governed by formal ISO accreditation and independence requirements, is often treated as secondary. Yet verifiers are uniquely positioned to identify structural weaknesses in project design, unrealistic timelines, or gaps in monitoring that can later derail buyer diligence.

When engaged early, verification can function as market preparation rather than a box-checking exercise, helping projects anticipate the questions that will ultimately determine commercial success. Often, issues that arise in verification are sure to arise in diligence.  Major changes to the project during verification are going to spook buyers.  The key is not to rush verification and to de-risk before engagement.

Common Failure Points

Across technologies, several patterns recur when projects struggle to advance. These include overly aggressive timelines that underestimate the duration and cost of diligence; underinvestment in monitoring, particularly digital systems that buyers increasingly expect; reliance on single-track monitoring approaches that fail to satisfy different reviewer preferences; and late engagement with verification experts, which can force redesigns at the worst possible moment.

These are rarely scientific failures. More often, they are process failures and/or misjudgments about how the market now evaluates credibility.

Toward a More Coherent Diligence Ecosystem

If the voluntary carbon market is to scale credibly, diligence must become more predictable without sacrificing rigor. That does not require lowering standards. It requires aligning expectations across registries, verifiers, buyers, and investors so that quality is not re-litigated from scratch at every stage.

For developers, this means treating diligence as a core development activity rather than a downstream compliance task. For buyers, it means recognizing how bespoke requirements shape market participation. For the market, it means acknowledging a simple truth: quality is not a label. It is a process.

About the Author

David LaGreca is the managing director of Carbon Markets Services, EcoEngineers, an LRQAcompany, with experience in all major greenhouse gas (GHG) programs across the Americas. Mr. LaGreca has brought projects through every phase, from conception through financing, methodology development, project registration, and verification. He has worked on hundreds of diverse projects, including reforestation, energy, methane abatement, blue carbon, and novel carbon removal technologies. He has developed and audited GHG inventories for communities, companies, and governments. Mr. LaGreca works to strategically align projects with markets to make decarbonization a viable business

Read more: “We Do A Great Job At Helping People Come To Market With Their Carbon Credits” – Roxby Hartley, PhD, Climate Risk Director At EcoEngineers

Canada’s Clean Fuels Market: What 2025 Clarified And What 2026 Will Test

This article was originally published in Biomass Magazine on March 31, 2026.

By Sally Taylor

For U.S. clean fuel producers looking north, 2025 brought much-needed clarity to Canada’s policy landscape, and 2026 will test how investable that clarity really is. Over the past year, Canadian federal policymakers made a series of targeted adjustments that directly affect cross-border market participants: refining guidance under the Clean Fuel Regulations, proposing focused amendments to address domestic competitiveness, reworking carbon pricing at the consumer level, and introducing time-limited incentives to stabilize Canadian production. Together, these moves reshaped not only the regulatory framework, but also how U.S. producers evaluate risk, return and strategic fit in the Canadian market.

In 2026, the question for U.S. producers is no longer whether Canada is committed to clean fuels; that commitment is clear. The question is how predictable, durable and navigable will the system be for companies accustomed to a very different U.S. policy environment, and how valuable will the market be?

2025: Reducing Friction, Not Raising Ambition 
One of the most critical and often overlooked themes of 2025 was the Canadian government’s effort to reduce friction within the existing policy framework, rather than dramatically expand it. Updated CFR guidance clarified credit creation, verification expectations and reporting mechanics. For many regulated parties, this did not change core compliance obligations, but it did improve confidence where uncertainty had previously slowed investment or delayed market entry. Greater clarity allowed companies to move forward or, just as importantly, reassess projects that no longer aligned with the more straightforward rules.

For U.S. producers, this distinction matters. The Canadian market is often evaluated through a U.S. lens that prioritizes the magnitude of incentives. In 2025, Canada signaled that regulatory certainty and consistency would be the primary value proposition.

The introduction of a new electric vehicle crediting pathway within the CFR fuel life cycle analysis model further reinforced this approach. Rather than positioning electrification as a replacement for liquid and gaseous fuels, Canada is treating transportation decarbonization as a portfolio challenge. For producers exporting renewable fuels into Canada, this signals coexistence.

Sending a Signal Without Rewriting the System 
The Canadian federal government’s decision to pursue targeted CFR amendments rather than a wholesale rewrite is instructive, particularly for foreign producers assessing long-term exposure. Rather than reopening the entire regulatory structure, policymakers focused on specific pressure points: domestic competitiveness, supply resilience and insulation from international policy volatility.

Proposals such as domestic content considerations and potential credit multipliers were framed less as protectionist measures and more as stabilization tools designed to preserve Canadian production capacity.

For U.S. RNG developers and other clean fuel producers, this approach introduces both opportunity and complexity. It creates optionality for projects aligned with Canadian priorities, while also underscoring the importance of understanding policy intent, not just regulatory language. The Canadian system rewards alignment and durability over short-term arbitrage.

Reflecting Global Realities, Not a Philosophy Shift 
The announcement of a time-limited biofuel production incentive, supporting Canadian biodiesel and renewable diesel producers through 2026 and 2027, represented the clearest acknowledgment of global market dynamics. This incentive isn’t meant to fundamentally change the Canadian market or replicate the U.S.-style subsidies forever. Instead, it recognizes that Canada’s clean fuels industry is part of a closely linked North American system, where shifts in U.S. federal incentives can swiftly impact the competitive landscape. 

For U.S. producers evaluating exports or partnerships in Canada, the message is nuanced: incentives may appear smaller or more targeted, but they are deployed strategically. The incentive functions as a bridge, not a destination, thus buying time for domestic supply while preserving long-term regulatory integrity.

Carbon Pricing Rebalanced, Not Abandoned 
The removal of the consumer carbon tax in 2025 drew significant attention, particularly from outside Canada. Its implications for clean fuels, however, are often misunderstood. While consumer-facing carbon pricing was eliminated, industrial carbon pricing through the Output-Based Pricing System remained intact. For clean fuel producers and compliance entities, this distinction is critical. The OBPS continues to anchor carbon value within the industrial economy, preserving a meaningful price signal for emissions reductions without placing direct costs on households.

For U.S. producers accustomed to more volatile or incentive-driven carbon markets, this represents a different kind of stability—one grounded in industrial compliance rather than consumer behavior.

What 2026 Will Test 
As Canada enters 2026, its clean fuels framework moves into a new phase. The rules are largely in place. Guidance has improved. Amendments are under consideration. Incentives are defined, if temporary. The year ahead will test execution, integration and strategic discipline, particularly for companies operating across borders.

Author: Sally Taylor   
Director of Strategic Development, EcoEngineers 

EcoEngineers Named Best Verification Company in North America

2026 Environmental Market Rankings by Environmental Finance lists EcoEngineers as Best Verification Company in Three Categories

EcoEngineers, an LRQA company, has been named Best Verification Company in North America by Environmental Market Rankings by Environmental Finance.

The company also earned Best Verification Company in Renewable Identification Numbers (RINs) and Best Verification Company and Renewable Natural Gas (RNG) Markets.

The Environmental Market Rankings are based on votes from market participants and recognize leading firms across global environmental and carbon markets. The awards highlight EcoEngineers’ continued leadership in regulatory compliance, carbon accounting, and independent verification services supporting renewable fuels and low-carbon energy markets.

2026 is the company’s first time being named Best Verification Company in North America, which includes the U.S., Canada and Mexico, and the RNG market, highlighting its growing role in compliance, certification, and carbon modeling across North America and Europe. It also marks the second consecutive year in the RINs Market – Best Verification Company ranking.

“This tremendous honor is a testament to the strength and dedication of our team in supporting companies build validated, defensible evidence supporting their sustainability claims,” said Shashi Menon, CEO of EcoEngineers. “Environmental markets are constantly evolving, and with that velocity of change, there is greater scrutiny, higher standards, and increased demand for transparency. Our team is proud to help clients navigate this complexity and close the gap between our client’s ambition and the proof in their data, across North America and globally.”

The 2026 Environmental Market Rankings recognition underscores EcoEngineers’ commitment to delivering independent verification services that strengthen environmental markets and support the energy transition. The rankings reinforce the market standing of their verification teams, signaling trusted expertise, consistency, and independence to clients, regulators, and market participants across the region.

Global Assurance and Accredited Verification Services

EcoEngineers supports companies to manage their sustainability reporting through second- and third-party audits, pre-verification, gap analyses, internal methodology development, and hot-spot mapping, among other things. The team’s technical capabilities expanded as a result of its acquisition by LRQA and range from regulated biofuel and carbon markets around the globe including U.S. tax credit verifications such as those under 45Z and 45V to voluntary sustainability reporting of scopes 1, 2, and 3 under various International Organization for Standardization (ISO) frameworks, the Greenhouse Gas (GHG) Protocol, Science Based Targets initiative (SBTi), Task Force on Climate-related Financial Disclosures (TCFD), etc.

Services ensure compliance with regulatory programs, including the European Renewable Energy Directive (RED), Emissions Trading Scheme (UK ETS, EUETS, NEA), the U.S. Renewable Fuel Standard (RFS), California Low Carbon Fuel Standard (LCFS), Oregon Clean Fuels Program (CFP), the Canadian Clean Fuel Regulation (CFR) and others. Through rigorous, science-based measurement, reporting, and verification (MRV) protocols, the company safeguards the integrity and accuracy of clients’ sustainability declarations across environmental markets.

EcoEngineers and LRQA together are accredited by more than 45 independent accreditation bodies worldwide and conduct thousands of audits annually of biofuel, sustainability, and GHG claims, and environmental management systems. They have a combined team of more than 1,000 auditors specializing in sustainability reporting and environmental and energy audits across the Americas, Europe, the Middle East, Africa, and Asia Pacific.

Specifically, EcoEngineers is accredited by the American National Standards Institute (ANSI) National Accreditation Board (ANAB) as a GHG verification body in accordance with ISO/IEC 17029:2019, ISO 14065:2020, and ISO 14064-3:2019. Its scope of accreditation includes verification of GHG emission reductions and removals at the project level under ANAB Group 01 (fuel combustion) and Group 03 (Land Use and Forestry), as well as verification of applications and reports under the Canadian Clean Fuel Regulations, including Sector 2 – Renewable/Bio/Low-CI Fuels and Sector 4 – Green Hydrogen.

Most recently, EcoEngineers and LRQA were approved by the Roundtable on Sustainable Biomaterials (RSB) to provide certification services under the RSB standard. This recognition places the company among a select group of organizations qualified to evaluate and certify biofuel and biomaterial companies navigating European and global renewable energy regulations.

Core LRQA GHG & ESG Verification Services

In addition to EcoEngineers’ environmental market verification capabilities, LRQA brings a broad suite of globally recognized GHG and environmental, social, and governance (ESG) assurance services that extend the value of the combined portfolio. These include:

GHG Verification Services:

  • Organizational carbon footprint verification under ISO 14064‑1
  • Verification engagements under ISO 14064‑3 for both voluntary and mandatory reporting schemes
  • Scope 1, 2 and 3 emissions verification aligned with the GHG Protocol
  • Product Carbon Footprint (PCF) verification under ISO 14067
  • Net‑zero and carbon neutrality verification, including ISO14068
  • Technical readiness assessments for SBTi target‑setting and transition‑plan validation
  • Sector‑specific GHG assurance (energy, manufacturing, industrials, transportation, logistics)

ESG & Sustainability Assurance:

  • Non‑financial reporting assurance under ISAE 3000
  • Limited or reasonable assurance over CSRD/ESRS climate‑related disclosures
  • Supply‑chain ESG assessments and assurance for responsible sourcing, human rights, and due‑diligence frameworks
  • Verification of sustainability performance indicators aligned with global ESG standards and investor frameworks

Together, EcoEngineers and LRQA offer an integrated global assurance platform across climate, carbon, biofuels, and sustainability reporting, covering regulated programs, voluntary markets, and corporate ESG disclosures.

For more information, contact: clientservices@ecoengineers.com

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 quality assurance to safety, cybersecurity, climate performance and responsible sourcing, LRQA works with clients to identify risks across their businesses. LRQA 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.

A Guide to Complying with New EV Verification Requirements

Originally published in EV Magazine on February 24, 2026.

By Daniel Ciarcia, Senior Carbon Consultant, EcoEngineers

EcoEngineers’ Daniel Ciarcia explains EV verification requirements in California and Canada and why organisations should begin work on these now.

EV charging has become an increasingly important pathway for reducing transportation emissions and for generating compliance credits under major fuel programmes.

Beginning with the 2026 reporting year, California’s Low Carbon Fuel Standard (LCFS) will now require third-party verification of EV charging credits by an accredited verification body (VB). Under Canada’s Clean Fuel Regulations (CFR), many operators will be verifying their EV credits for the first time because the regulation is new. For many charging operators, fleet owners, site hosts and municipalities, this will be the first time their EV data is formally audited. 

Verification under LCFS and CFR

Under the California LCFS, EV charging credits are now treated like other fuel pathways. Beginning with 2026 operating data, entities generating EV credits must submit annual reports that are independently verified by an accredited verification body, with verification statements due by August 31, 2027. While the first verified reports for LCFS are not due until 2027, the data being audited is generated in 2026. Now is the critical time to prepare. 

Under Canada’s CFR, EV charging is recognised under Compliance Category 3 as a credit-generating activity that displaces fossil fuels. Registered Credit Creators, such as charging site hosts and charging network operators, must continue to submit annual credit-creation reports, which have always been subject to third-party verification. CFR is regulated under the Canadian Environmental Protection Act, meaning non-compliance can carry serious penalties.

In both programmes, verification is no longer optional. Many organisations do not realise they are required to obtain third-party verification.

What are LCFS and CFR credits?

Under LCFS and CFR, credits can be generated from vehicle charging activity at public charging stations, fleet depots, workplace charging and certain multi-family properties with unassigned chargers. In these cases, the owner (site host) or operator of the charging equipment may be the credit generator.

Who is eligible?

Organisations that have registered and have approved pathways can generate credits under these programmes. Credits are generated through charging activity and reflected in quarterly reports for CA-LCFS filed in CARB’s LCFS Reporting Tool (LRT), and annually in Canada through Credit and Tracking System (CFR-CATS).

 

Three-step guide to verification

Step 1: Select your third-party VB. As required by both the California LCFS, Canada CFR and most carbon credit programmes, a third-party VB is required to confirm that the credits claimed are true and accurate and no double-counting has taken place. It is important for your VB to have the following credentials.

Accreditation status:

  • California LCFS: Requires specific accreditation from the California Air Resources Board (CARB).
  • Canada CFR: Requires specific accreditation from an Environment and Climate Change Canada (ECCC) designated body.
  • Both Programmes: Must have mechanisms to prevent and resolve conflicts of interest.
    • Must be a member of the International Accreditation Forum.
    • Must have policies for technical training related to verification.
    • CA-LCFS must meet ISO/IEC 17011 standards, while CFR must meet ECCC Methods for Verification and Certification.

Both programmes require the VB to be accredited to ISO/IEC 17029 with scope of ISO 14065 and ISO 14066. Both also require the employment of a qualified independent reviewer with the same competencies as the team leader.

EcoEngineers is an accredited VB in California LCFS, Canada CFR, Oregon and Washington.

Step 2: Ensure metering and data are audit-ready. One of the most important and often underestimated requirements is measurement devices.

Both programmes require meters that:

  • Meet accuracy and reliability standards
  • Are properly installed and calibrated
  • Can clearly measure electricity dispensed to EVs
  • Are supported by documentation (make, model, serial number, calibration records)

Even if meters were calibrated by manufacturers at installation, entities must retain documentation to prove it. Missing or non-compliant meter records can result in adverse verification findings and potentially disallowed or reduced credits.

In addition, entities must retain session-level data internally, even if only aggregated values are submitted to regulators. Your verifying body would be able to help you ensure you are in compliance, so you don’t lose any credits unexpectedly.

Ultimately, accurate recordkeeping is essential, so reports should be backed by documentation that can pass an audit.  

Step 3: Prepare for the verification process. A typical verification includes:

  • Risk and materiality assessments
  • Data sampling and testing
  • Document reviews
  • Site visits 
  • Issue resolution
  • Submission of a verification opinion to regulators

A complete verification cycle usually takes around 90 days, depending on preparedness and responsiveness. 

 

Daniel Ciarcia is a Senior Carbon Consultant at EcoEngineers, an LRQA company, with a focus on electric vehicles, renewable electricity and energy transition programmes.

 

45Q Credits Amid EPA GHG Reporting Uncertainty

This article was originally published in Ethanol Producer Magazine on February 23, 2026.

By Roxby Hartley, Ph.D. and Chelsa Oren

For ethanol producers investing in carbon capture and storage, Section 45Q, the U.S. tax credit for carbon dioxide (CO2) sequestration, remains a cornerstone incentive. At the same time, recent regulatory developments have introduced uncertainty around how producers will document compliance for calendar year 2025.

The issue is not whether the credit is available; it is how eligibility will be demonstrated.

It is also important to note that Section 45Q is not limited to geologic storage. CO2 used for enhanced oil recovery (EOR) or other utilization pathways may also qualify as eligible carbon capture under 45Q, provided the CO2 is securely stored or its lifecycle emissions are appropriately quantified and verified in accordance with U.S. Internal Revenue Service and U.S. Environmental Protection Agency requirements.

Historically, 45Q compliance for geologic storage has been closely tied to the EPA’s Greenhouse Gas Reporting Program (GHGRP), specifically Subpart RR. Facilities captured CO2, injected it under approved permits, monitored storage performance and reported results annually through EPA’s electronic reporting system. Those reports formed the basis for certifying eligible CO2 volumes on IRS Form 8933.

In September 2025, the EPA proposed removing most GHGRP reporting requirements, including Subpart RR, after 2024. As of early 2026, the agency has not yet decided whether to discontinue reporting or to launch a revised electronic Greenhouse Gas Reporting Tool (e-GGRT) for 2025 data. Because existing U.S. Treasury regulations still reference EPA reporting as the mechanism for demonstrating secure geological storage, this lack of clarity has real implications for ethanol producers planning to claim the credit.

To address this gap, the IRS issued interim guidance in December 2025 (Notice 2026-1). The guidance outlines two compliance paths for calendar year 2025, depending on whether the EPA launches its reporting system by June 10, 2026. Producers should now prepare for both outcomes.

Why EPA Reporting Still Matters 
Under current rules, CO2 qualifies as securely stored for 45Q purposes only if injection and monitoring meet EPA standards. Subpart RR defines those standards. It requires mass-balance accounting of injected CO2, monitoring to confirm containment and annual reporting of results. 

The IRS safe harbor does not change these technical expectations. What changes is the verification pathway if EPA reporting is unavailable. Instead of submitting data directly to the EPA, producers may rely on third-party technical certification. The underlying monitoring, documentation and engineering rigor remain the same. This distinction is important. The safe harbor is not a simplified option. It is an alternative method for demonstrating compliance when the EPA’s reporting system is not accessible.

Two Compliance Paths for 2025

If EPA Launches e-GGRT: 
If the EPA launches the reporting system for reporting year 2025 by June 10, 2026, the safe harbor does not apply. In that case, ethanol producers must submit a complete Subpart RR Annual Report through the EPA system, consistent with prior practice.

All monitoring data, mass-balance calculations and supporting documentation must be reported electronically. Successful submission satisfies the regulatory requirement for secure geological storage and allows the taxpayer to certify eligible CO2 volumes on its federal tax return. Producers should assume this remains the default scenario until EPA confirms otherwise. Reporting accounts, credentials and internal workflows should remain active.

If EPA Does Not Launch e-GGRT: 
If the EPA does not launch the reporting system by June 10, 2026, Notice 2026-1 allows taxpayers to rely on a safe harbor for calendar year 2025. Under the safe harbor, the producer must still prepare a full Subpart RR–compliant Annual Report. 

Content requirements are unchanged. What changes is who reviews and certifies the report. Instead of submitting the report to the EPA, the taxpayer must provide it to a qualified independent engineer or geologist. The certifier must be licensed in at least one U.S. state and independent of the taxpayer and any credit claimant.

The certifier must attest, under penalties of perjury, that the project complies with Subpart RR as in effect on December 31, 2025, and that the report is accurate and complete. All documentation and certification must be finalized by the time the taxpayer files its federal income tax return. The materials are retained in the taxpayer’s records and must be available upon request.

For producers accustomed to EPA-centered compliance, this represents a shift. Responsibility for demonstrating compliance moves more directly to the project team and its technical advisors.

What Ethanol Producers Should Be Doing Now 
The most significant risk in the current environment is delay. Producers should continue operating as though Subpart RR reporting will be required. Monitoring systems, data collection protocols and internal quality controls should remain fully aligned with EPA requirements. The safe harbor does not excuse gaps in data or incomplete monitoring, and any deficiencies will surface during third-party certification.

Producers should also begin engaging qualified professional engineers or geologists now. Under the safe harbor, independent technical certification is mandatory. There is a limited pool of professionals with appropriate licensure and carbon storage experience, and demand is likely to increase as the June deadline approaches.

Early engagement allows time to review monitoring plans, validate data workflows and identify issues while corrective action is still possible. It also reduces the risk of certification delays that could interfere with tax filing deadlines.

In parallel, producers should begin assembling the structure of their 2025 annual report. Facility descriptions, permitting information, injection well details and monitoring methodologies can be drafted in advance. Treating the report as a working document reduces schedule pressure and improves defensibility.

Finally, producers should plan for dual compliance until the EPA provides clarity. Preparing both an EPA-ready submission and a safe harbor certification package may involve some duplication, but the cost is modest relative to the value of the credit and the risk of noncompliance.

Supporting Compliance Through the Transition 
Work with a third-party verification body on 45Q compliance, monitoring and verification program development, and third-party certification readiness. Whether EPA reporting proceeds or the safe harbor applies, the technical standard remains Subpart RR. Early involvement of qualified engineers helps ensure that monitoring programs are aligned with those standards and that documentation withstands review.

Looking Ahead 
June 10, 2026, is the key date. Producers should closely monitor EPA announcements, Federal Register notices and updates to the GHGRP program. Confirmation that e-GGRT is operational—or that Subpart RR reporting will not proceed—will determine which compliance path applies.

Additional IRS guidance is also possible. Notice 2026-1 is interim and limited to calendar year 2025. Revised regulations are expected for future years.

For now, the prudent approach is to:

• Prepare and maintain technical discipline

• Engage qualified professionals

• Build documentation early

Producers that do so will be positioned to claim the 45Q credit with confidence, regardless of how EPA ultimately resolves its reporting program.

Authors: Roxby Hartley, Climate Risk Director EcoEngineers, an LRQA company 
rhartley@ecoengineers.us

Chelsa Oren, Ethanol and Biodiesel Service Director EcoEngineers, an LRQA company 
coren@ecoengineers.us 

EcoEngineers Recognized Among Top 10 Energy Consulting Companies Worldwide

EcoEngineers (Eco) has been named one of the Top 10 Energy Consulting Companies globally by Energy Digital. This recognition highlights our dedication to guiding clients through the complexities of the energy transition and our commitment to creating a sustainable future. 

We are proud to be featured alongside global leaders in the field, including Bain & Company, Boston Consulting Group (BCG), Deloitte, ERM, KPMG, McKinsey & Company, Oliver Wyman, PwC, and Schneider Electric, reaffirming our dedication to delivering innovative solutions that foster a more sustainable future.

For more information, visit the full article on Energy Digital here.

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.

EcoEngineers: Unlocking Revenue Through Life-Cycle Analysis

The following is an article originally published by Sustainability Magazine on September 24, 2025.

By Laith Amin, Vice President, Growth and Strategic Development at EcoEngineers

 

Laith Amin, Vice President, Growth and Strategic Development at EcoEngineers, on turning compliance into business advantage

For years, the energy and industrial sectors have treated compliance as a necessary cost of doing business. Regulations were viewed as hurdles, tax credits as short-term windfalls and carbon accounting as a paperwork exercise. But we are now at a turning point: life-cycle analysis (LCA) is proving that when done strategically, compliance can evolve into a powerful tool for unlocking revenue and securing long-term competitiveness.

Recent policy changes, including the passage of the One Big Beautiful Bill Act (OBBBA) in the US, have only sharpened the stakes. By linking major incentives directly to LCA outcomes, regulations elevate accurate carbon intensity modelling to a financial imperative. Industries such as ethanol, hydrogen, sustainable aviation fuel (SAF), renewable diesel, biogas and carbon dioxide removal are among those where LCA results directly determine tax credit values, access to markets and revenue potential.

With tax credits in the US Inflation Reduction Act (IRA), such as 45V for hydrogen, 45Z for clean fuels and 45Q for carbon capture now tied directly to carbon intensity outcomes, a single point reduction in an LCA score can often translate into millions of dollars of value. Consider an ethanol plant producing 100 million gallons annually: improving its carbon intensity (CI) by just one point could yield US$2m in additional revenue. That’s not an engineering retrofit—it’s the result of smart modelling, accurate data and a disciplined approach to understanding your environmental footprint.

The Power of Measurement

At its core, LCA provides a structured methodology to measure a product’s environmental impact from raw material extraction through end-of-life. By mapping every stage of production and use, it enables organisations to identify hotspots where emissions or resource use are highest, then prioritise improvements.

Small shifts in carbon intensity can deliver outsized results. For example, hydrogen developers achieving a carbon intensity below 0.45 kg CO₂ per kilogram of hydrogen may qualify a project for the most lucrative federal tax credits, worth millions of dollars annually.

LCAs also play a central role in the voluntary carbon markets (VCMs), where methodologies for credits such as biochar, afforestation or carbon removal projects are built directly on LCA principles. Here, accurate modelling is essential not just for compliance but for generating and monetising high-integrity credits. Beyond ethanol and hydrogen, fuels such as SAF, renewable diesel and biogas all rely on LCAs to determine eligibility for incentives, establish market competitiveness and build trust with stakeholders.

Managing Risk Across Borders

LCA is not only about maximising credits; it is also about mitigating risks. With mechanisms such as the European Union’s Carbon Border Adjustment Mechanism (CBAM) coming online, exporters who fail to validate their emissions data could face costly trade penalties. Verification requirements vary across jurisdictions, and companies must be prepared to demonstrate compliance not just once, but year after year. Here again, LCA is more than an academic exercise, it is a passport to global market—and as we look forward, few will be surprised to see regulators set emissions intensity factors on the high side as a way to encourage organizations to build LCA data and modelling competency.

Building Strategic Competence

Organisations face a choice. Some will outsource LCA entirely to accredited third parties, ensuring compliance but limiting their ability to test scenarios against operational improvements. Others are moving toward building in-house competence, developing teams that can run their own models, conduct sensitivity analyses and embed LCA into daily operations.

The most successful firms will blend both approaches: leveraging external expertise for verification and regulatory alignment, while cultivating internal capabilities to remain nimble and seize emerging opportunities.

From Compliance to Value Creation

The lesson is clear: LCA is no longer optional. It is a strategic requirement for accessing incentives, managing risk and creating shareholder value. Companies that treat LCA as a core business process will not only stay ahead of regulators, they will refine their operating model to unlock new revenue streams, strengthen customer trust and position themselves as leaders in the energy transition.

For those ready to take the next step, there are communities of practice forming where regulators, scientists and industry peers come together to explore best practices and hands-on applications of LCA. One such opportunity is the upcoming LCA Academy in Houston, taking place on October 7-8, hosted by EcoEngineers and LRQA—it’s designed as a deep dive for both leaders and practitioners who want to strengthen their capabilities, reduce uncertainty and turn compliance into a competitive advantage.

The future belongs to organisations that measure to improve rigorously, act strategically and treat compliance not as a burden, but as an advantage. LCA is the key to making that shift, and the time to start is now.

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

Laith Amin, Vice President, Growth and Strategic Development | lamin@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.

Regenerating Agriculture: Coordinating Action Across the Global Food System

The following is an article originally published by Newsweek on September 18, 2025.

 

The global food system is at a crossroads. Feeding a rapidly growing population while cutting emissions demands nothing short of a transformation in how we farm, finance and fuel the future. Regenerative agriculture and bioenergy are at the center of this shift—restoring soils, reducing emissions and creating new value streams for farmers and communities. This report brings together insights from Rabobank, Arva, Sevana Bioenergy, EcoEngineers, South Jersey Industries, LF Bioenergy and U.S. Ag & Dairy Sustainability Advising to show how collaboration, technology and market innovation can regenerate agriculture at scale.

Click here to download the full report.

 

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

Brad Pleima, President | bpleima@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.

Section 45Z Is Here: Act Fast, Monetize Smart

The following is an article originally published by Ethanol Producer Magazine on July 25, 2025.

By McCord Pankonen, Managing Director, North America Biofuels

The Section 45Z Clean Fuel Production Tax Credit (PTC) under the Inflation Reduction Act of 2022 (IRA) was created to incentivize the production of low-carbon transportation fuels in the U.S. With the signing of the One Big Beautiful Bill Act (OBBBA) into law on July 4, 2025, the program’s framework has shifted to align with this administration’s priorities and begun to show signs of stabilization. It now offers a longer timeline, more favorable parameters for crop-based fuels, and greater clarity, though further guidance is still forthcoming. 

The tax credit, originally set to expire in 2027, has been extended through 2029. The new law also eliminates indirect land-use change (ILUC) penalties from carbon scoring, which is good news for corn-ethanol, soy-based biodiesel, and other crop-based fuels. For biofuel producers, this means more credit value, more time to claim it, and an open path forward.

Uncertainty Has Faded, and Action is Now Required

While final Internal Revenue Service (IRS) guidance is still pending, the foundation of the program is well defined. Clean fuel producers should no longer be waiting; they can now move forward with critical planning and preparation. The structure of the tax credit is based on carbon intensity (CI) scoring through the 45ZCF-GREET model, third-party validation, and tax credit transferability. The emerging market signals are clear, where credit value will be closely tied to lifecycle emissions data, audit-ready documentation, and proactive engagement with qualified validators, brokers, and advisors.

Facilities that update their CI modeling, verification planning, and documentation preparation now will be in a much stronger position to monetize early 2025 production and secure value. This includes establishing a defensible life-cycle analysis (LCA), aligning internal compliance requirements, and vetting how prevailing wage or apprenticeship requirements may affect credit eligibility. Delaying action could mean missing early monetization opportunities and losing a competitive edge in the low-carbon fuel market. The time for action is now.

Tips to Prepare and Execute

Execution starts with building a clear, facility-specific tax credit roadmap. Producers should analyze how their current operations score under the required CI modeling and identify technical and operational upgrades being considered to achieve lower CI scores and, hence, higher credit value. Proactive modeling, real-time CI monitoring, and third-party CI reviews are important steps to gaining assurance. Investments in carbon capture and sequestration (CCS), renewable electricity, heat recovery, and energy efficiency can all improve CI scores and increase Section 45Z value.

Equally important is systematizing compliance documentation. IRS rules will require proof, not assumptions. That means aligning your finance, operations, and compliance teams now to collect verifiable data, track labor requirements tied to prevailing wage rules, and prepare supporting documentation for LCA filings and potential credit transfers. This process starts with an understanding of the required documents, which can be done through engagement with verification bodies and tax preparers. Don’t underestimate obtaining training for key team members responsible for compliance, or consider hiring an advisory firm for support when in-house expertise is not available. 

Monetizing the Section 45Z Credit: Be Ready to Transact

The Section 45Z credit is transferable, meaning it can be sold to buyers with tax liability, unlocking immediate cash flow. But in this emerging market, buyer confidence is key. That confidence comes from well-documented carbon scores, verified models, and clean audit trails that demonstrate compliance with IRS expectations. Buyers will prioritize credits backed by rigorous third-party validation, clear LCA submissions, and accurate documentation of CI reductions. Facilities that can present a complete, auditable compliance package will be first in line for competitive offers and smoother transactions. Just like in renewable energy markets, the ability to execute with precision and transparency will directly affect pricing, speed of transfer, and demand from credit purchasers. Building that level of readiness now will position producers to monetize quickly and at maximum value.

Now is the time to engage LCA experts, brokers, tax advisors, and insurance partners. The most competitive buyers will look for facilities that are “execution ready” with clear documentation, validated modeling, and third-party signoff already in place. Facilities that are prepared will be first in line for the highest offers and fastest monetization timelines.

Think Beyond Section 45Z: Stackable Opportunities

Section 45Z is a powerful incentive on its own, but its impact grows when combined with other programs. Biofuel producers engaged in CCS, for instance, will be eligible for either Sections 45Z or 45Q. Determining which tax credit is most valuable depends on an individual producer’s CI reduction roadmap. A lower CI score boosts credit value under Section 45Z, and California’s Low Carbon Fuel Standard (CA-LCFS) or Canada’s Clean Fuel Regulation (CFR) programs concurrently. Stacking incentives isn’t just possible, it’s a smart strategy. Facilities should assess where credits overlap and ensure they’re maximizing value across federal, state, and export programs.

Policy Engagement and Internal Readiness

As Section 45Z rules are deployed, producers should remain engaged in policy discussions and advocacy. Participation in technical working groups, trade associations, and regional initiatives helps ensure that your facility’s perspective is represented. Staying connected to the rulemaking process not only gives early visibility into program requirements but also creates opportunities to influence guidance in ways that support your business model.

Internally, now is the time to build your Section 45Z execution team. Whether it’s in-house or supported by external experts, success will require cross-functional coordination between engineering, finance, compliance, and legal stakeholders. Clear ownership of documentation, modeling, and tax strategy across departments will be essential to streamline credit generation, validation, and monetization once the program goes live. Adding staff to support carbon-reduction initiatives or teaming with the right advisory partner may be options worth evaluating. 

The Bottom Line

Section 45Z is an actionable tax credit with strong bipartisan backing and a favorable runway through 2029. The incentives are meaningful, the framework is coming into focus, and the execution path is much clearer. Clean fuel producers who prepare now by modeling their CI, validating documentation, and aligning stakeholders will be positioned to claim the credit without delay, monetize it efficiently, and outpace the competition.

The opportunity is real. The direction is clear. It’s time to execute. Let’s go!

About the Expert

McCord Pankonen is the managing director of North America Biofuels at EcoEngineers. Mr. Pankonen has a rich history of achieving success by advancing renewable energy and agriculture business initiatives. He has more than 22 years of experience leading ethanol production facilities, assembling high-performing teams, and sustaining operational excellence. Mr. Pankonen is a recognized talent who can innovate and penetrate developing markets with profitable technologies that offer sustainable solutions for end users. He possesses an executive presence and can create critical relationships at all levels that are paramount to achieving organizational goals. 

 

For more information about our Ethanol and Biofuels services and capabilities, contact: 

McCord Pankonen, Managing Director, North America Biofuels | mpankonen@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.