Category: News

FEW 2025 Podcast Series: Live with EcoEngineers

In a recent episode of Ethanol Producer Magazine’s podcast series, McCord Pankonen, Managing Director for North America Biofuels at EcoEngineers, joined host Anna Simet at the 2025 Fuel Ethanol Workshop (FEW) in Omaha, Nebraska, to discuss the evolving landscape of carbon intensity (CI) tracking and its implications for the ethanol industry. 

Pankonen emphasized that the ethanol industry is at a pivotal moment. As regulatory frameworks and voluntary programs increasingly prioritize carbon performance, producers are being called to demonstrate not just compliance but also leadership in sustainability. He noted that accurate life-cycle analysis (LCA) is no longer a niche concern; it’s becoming a core business function. This shift is driven by both policy developments and market expectations, particularly from buyers seeking low-CI fuels.

A key theme in the discussion focused on the need for credible, third-party-verified data. Pankonen highlighted how voluntary consensus standards bodies are helping to establish trust in carbon accounting practices. He also pointed to the importance of aligning methodologies across jurisdictions to ensure consistency and comparability.

The conversation also touched on the role of digital tools and quality assurance programs (QAPs) in streamlining data collection and verification. Pankonen advocated for systems that are both rigorous and user-friendly, enabling producers to focus on operational improvements while maintaining audit readiness.

Looking ahead, Pankonen expressed optimism about the ethanol industry’s ability to lead in carbon-reduction innovation. He underscored the value of collaboration between producers, regulators, and technology providers in building a transparent and efficient carbon marketplace.

Click below to watch the full podcast interview. 

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.

Tierrasphere Introduces A Pioneering Photosynthesis-Based Durable CDR Methodology

The following is an article originally published by Carbon Herald on June 25, 2025.

At the seventh edition of London Climate Action Week, ecology-focused carbon removal company Tierrasphere unveiled the world’s first carbon dioxide removal (CDR) methodology based on photosynthesis-driven oxalate-carbonate mineralization.

This groundbreaking methodology comes at a time when degrading soils already threaten food security and business resilience, and it presents a solution that restores soil vitality and ensures carbon permanence—a critical component for high-integrity CDR. 

Tierrasphere CEO Marcela Flores stated, “This methodology marks a historic step toward scalable, nature-aligned, highly durable, and verifiable carbon removal. By harnessing the elegance of photosynthesis to drive durable carbon mineralization, we’re enhancing one of Earth’s oldest biological processes into a measurable, durable, and powerful climate solution.”

The durable CDR method unlocked through photosynthesis-driven oxalate-carbonate mineralization leverages regenerative agroforestry food systems that tackle atmospheric CO2 through the naturally occurring photosynthesis process, converting carbon into stable minerals via the oxalate-carbonate pathway.

As Tierrasphere highlights, while regenerative agriculture CDR approaches sequester CO2 as soil organic matter that lacks permanence, the method of photosynthesis-powered oxalate-carbonate mineralization locks away carbon geologically, providing an energy-efficient solution that offers durability, transparency, and scalability.

In an interview with Carbon Herald, Flores points out that industrial agriculture has contributed to a nature loss of 73% since the 1970s. 

She goes on to explain that while regenerative agriculture is widely recognized as a powerful tool for addressing climate change, its reliance on organic soil carbon poses a challenge for participation in carbon markets. 

Organic carbon is inherently unstable—it is part of the natural carbon cycle and constantly in flux—making it difficult to meet the durability requirements that carbon markets demand. 

“Our approach enhances the regenerative model by integrating inorganic carbon into soil systems. Unlike organic carbon, inorganic carbon is geologically stable and far more durable, offering a new, long-term pathway for carbon sequestration. This can unlock an additional layer of profitability for regenerative farmers by enabling access to more robust, verifiable carbon credit mechanisms,” Flores adds.

Tierrasphere’s concept aims to channel new sources of finance for nature-positive interventions to restore degraded land, yet it’s not exclusively focused on that.

Flores states, “We believe that systems like ours can bring new financial mechanisms into nature, supporting positive ways to grow our food, because we might not be seeing the consequences right now, but they are coming, and they’re coming fast.”

Relevant: LENs Report Reveals Major Gains In Regenerative Agriculture Across Europe

Funded by an InnovateUK grant and support from like-minded investors, the novel methodology was co-developed with scientific rigor by Tierrasphere’s in-house research team and leading experts from the University of Zurich, the Autonomous University of Yucatan, and the British Geological Survey (BGS).

To make sure the methodology follows industry compliance standards, Tierrasphere relied on input from EcoEngineers, a clean energy consulting, auditing, and advisory company recently acquired by LRQA.

Commenting on this collaboration, EcoEngineers CEO Shashi Menon shared, “At Eco, we show clients how to take their rigorous science-based methodology and make it market-ready. Robust measurement and verification standards layered on top of science are what is needed for integrity and scalability in the carbon removal market.”

Roxby Hartley, Ph.D., Director of Climate Risk at EcoEngineers, who has co-developed the methodology, shared with Carbon Herald that this project, which took several months to complete, involved sophisticated work on differentiating inorganic and organic carbon in the methodology, as both types of CO2 require different monitoring, reporting, and verification (MRV) approaches and offer different forms of permanence where separate risks of reversal had to be considered.

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

InnovateUK funding also enabled Tierrasphere to create a proprietary AI Engine tool that offers high-precision site selection and can serve as a valuable asset for project development in alignment with the newly released methodology. 

Flores says that this cutting-edge tool serves to flag sites that have the highest opportunity for the greatest amount of carbon removal. As she explains, to help build this tool, the Tierrasphere team looked into thousands of data points that are readily available, combining them with information from its own data points from the UK and Mexico. 

Going forward, the company intends to use technology and AI to lower the costs for MRV and measurements that determine the amount of carbon removal that has already happened.

Tierrasphere has opened a 30-day public feedback period for the methodology, ending on 25 July 2025, during which commentary can be sent to hello@tierrasphere.com. The methodology is available for download here.

Unlocking the Full Potential of SAF Markets

The following is an article originally published by Biobased Diesel™ on June 17, 2025.

Rigorous LCA and QAP participation is crucial for ensuring SAF market access, maximizing regulatory incentives and establishing confidence in a competitive global environment. 

Sustainable aviation fuel (SAF) has emerged as the cornerstone of aviation’s decarbonization strategy. Achieving market access, however, demands a robust commitment to carbon accounting, lifecycle analysis (LCA) and participation in a rigorous Quality Assurance Program and associated protocols. 

A defensible carbon-intensity (CI) score is the gateway to regulatory incentives, such as federal tax credits and carbon credits to participate in markets such as California, Oregon, Washington, British Columbia or Europe, enhance market value and ensure long-term viability. Without proper documentation, verification and rigorous carbon accounting, even the most innovative SAF producers may miss out on critical opportunities. 

Put simply, the CI score is a key entrance ticket to participating in regulatory and compliance market programs. Each LCA must be done accurately and in accordance with regulatory requirements to avoid potential compliance issues, which may impact a company’s financial health and future operations. Regulators often conduct rigorous audits and double-check disclosures to ensure accuracy and validity. This involves third-party verifications, site inspections and detailed reviews of submitted documentation. 

LCAs assess the environmental impacts associated with a fuel’s entire lifecycle—from feedstock sourcing to production, distribution and end-use. Developed initially to compare the environmental impacts of consumer goods, LCAs today form the scientific and technical backbone of nearly every low-carbon fuel regulation. 

For SAF producers, CI scores help determine renewable identification number (RIN) codes, California Low Carbon Fuel Standard credits, Carbon Offsetting and Reduction Scheme for International Aviation credits, and federal tax incentives like the section 45Z clean fuel production credit. Each jurisdiction or program may have a different carbon-modeling system, such as the Argonne National Laboratory’s Greenhouse Gases, Regulated Emissions and Energy use in Technologies (GREET) model, CA-GREET, or the International Civil Aviation Organization’s GREET. Furthermore, each system may carry distinct assumptions and default values, requiring careful navigation. 

Although not always required, SAF and renewable diesel producers, especially foreign entities and entities with complex feedstock supply chains, would find enrolling in the U.S. EPA’s Renewable Fuel Standard QAP beneficial to ensure SAF and renewable diesel comply with RFS regulations and prevent fraudulent activities. 

EPA’s QAP program ensures RINs are properly generated through audits of renewable fuel production conducted by independent third parties. It also provides an affirmative defense for the transfer or use of invalid RINs verified under an approved QAP. Buyers often do not accept the fuel without making sure it is fully in compliance. QAP compliance can also help streamline compliance requirements for other jurisdictions, reducing financial and resource burdens. 

LCA models can vary substantially, although all models should follow International Organization for Standardization (ISO) 14000 series standards. GREET tools dominate U.S. markets while CORSIA relies on ICAO-approved frameworks. Meanwhile, Renewable Energy Directive (RED III) compliance in Europe introduces another set of modeling expectations. 

ICAO, a specialized United Nations agency, develops international standards and regulations to support safe, efficient and environmentally responsible global air transport. Within this framework, CORSIA is ICAO’s key initiative to curb carbon emissions from international aviation. CORSIA aims to cap aviation emissions at 2020 levels by requiring airlines to offset any growth in CO2 emissions. 

One of the main pathways for airlines to reduce their offsetting obligations under CORSIA is through the use of CORSIA-eligible SAFs. Eligibility, however, hinges on meeting minimum lifecycle-emissions reductions. According to CORSIA, to be certified as a CORSIA-eligible fuel, SAFs must meet the CORSIA sustainability criteria, including a 10 percent reduction in lifecycle emissions compared to the petroleum-based jet-fuel baseline of 89 grams of CO2-equivalent per megajoule (gCO2e/MJ). The greater the emissions savings, the more effectively the SAF reduces an airline’s offsetting burden, making low-carbon fuels particularly attractive under the scheme. 

Each carbon-modeling system may handle key factors such as feedstocks, transportation emissions, process energy, land-use change and coproduct allocation differently. Successful SAF projects must report these inputs with accuracy to ensure that final CI scores are valid and verifiable across multiple jurisdictions. 

Regulatory landscapes are rapidly evolving around the world. Organizations that proactively invest in accurate LCA modeling, robust QAP and compliance protocols, and traceable supply chains will be best positioned to thrive in this competitive environment. Ensuring data quality, auditability and adaptability will be essential in securing both compliance and market leadership.

Author: Kristine Klavers
Managing Director, Houston, Low-Carbon Petroleum 
EcoEngineers 
kklavers@ecoengineers.us

The Road to Renewable Fuel Readiness Runs Through Feedstock Integrity

The following is an article originally published by Biodiesel Magazine on May 22, 2025.

By David Dix, Account Manager, Low-Carbon Petroleum (SAF, RD, and Carbon Markets)

As global efforts to decarbonize aviation and ground transport accelerate, the urgency to grow the hydroprocessed esters and fatty acid (HEFA)-based renewable diesel (RD) and sustainable aviation fuel (SAF) business has never been greater. Yet, for producers and developers of such projects, one of the biggest barriers to growth isn’t infrastructure—it’s sourcing consistent, traceable feedstock and complying with complex and evolving regulations. 

Despite these challenges, demand for SAF in the U.S. continues to climb. The market’s momentum underscores a growing urgency to overcome feedstock and compliance challenges. In February 2025, U.S. domestic demand for SAF was five times higher than the average monthly demand in 2024, as reflected in the U.S. Environmental Protection Agency’s D4 renewable identification number (RIN) generation data. (Figure 1)

Figure 1: U.S. Consumption of Domestically-Produced SAF

(Source: USEPA, EcoEngineers)

This surge in demand reflects more than just market enthusiasm—it signals a critical juncture for SAF and RD developers. As the industry scales, the ability to align innovative project concepts with the realities of feedstock availability and regulatory expectations becomes a defining factor in long-term viability.

The Feedstock Challenge 

To reach a final investment decision, SAF and RD project developers need long-term feedstock security. However, this is often complicated by geography. SAF and RD feedstocks such as used cooking oil (UCO), tallow, soybean oil and canola are often not produced in the same regions where the finished fuels are consumed. For example, UCO is often collected in densely populated urban centers or imported from Asia, whereas SAF production and consumption are frequently concentrated near airports or coastal hubs. This disconnect raises costs and increases lifecycle carbon intensity (CI), which can make it difficult to participate in credit programs like California’s Low Carbon Fuel Standard and similar state and provincial programs.

Technology flexibility adds another layer of investment costs. While most SAF-capable facilities can also produce RD, the reverse is often the case, requiring additional processing infrastructure. As SAF demand grows due to airline decarbonization targets and environmental, sustainability, and governance reporting, production flexibility—the ability to switch between RD and SAF—is becoming a strategic advantage for developers. However, adding SAF capacity to an existing RD facility adds capital expenditure and operational expenditure.

Traceability and Compliance Risks 

As feedstock values rise, so does the risk of fraud. For example, regulatory programs in the European Union and the United Kingdom restrict or cap many virgin oil feedstocks and create an incentive for UCO fraud in major UCO exporting countries. In some cases, suppliers may fry a single item in virgin oil and falsely label it as UCO to qualify for compliance programs. This not only undermines compliance integrity and increases scrutiny from regulators, but it also disincentivizes the proper end-of-life treatment of materials, as economic pressure favors labeling waste streams as renewable feedstocks, regardless of origin. Feedstock traceability tools that include detailed documentation of origin, transportation, and chemical analysis are now critical for maintaining regulatory alignment across jurisdictions.

Recent cases underscore the risk. In Norway, for example, retroactive credit callbacks were issued when imported tallow failed to meet compliance standards. These events signal the growing need for robust chain-of-custody systems and strict supplier verification.

Aligning Facility Design with Feedstock Geography 

Regional advantages must drive feedstock decisions. Tallow is abundant in cattle-producing regions like Texas, Montana, and Brazil. UCO thrives in countries with high rates of deep-frying, particularly across Asia. Woody biomass and agricultural residues are prevalent in the Pacific Northwest and southeastern U.S. Eschewing regional logic in favor of convenience often leads to high CI scores and lower credit values.

Furthermore, transportation emissions, energy inputs, and process efficiency can impact the CI score of the fuel. Therefore, facility siting decisions should also reflect access to both feedstock and low-carbon energy inputs.

Timing is Everything 

In one recent case, a production facility was built and feedstock secured, only for the company to realize that EPA pathway approval would take nine months to a year to complete. Early engagement with federal and state regulators, as well as third-party advisors with regulatory and compliance expertise, is essential to run in parallel to engineering, procurement, and front-end planning stages. This approach sets investors and stakeholders on a path to realizing long-term value creation for their RD and SAF investment. 

It is also important for SAF and RD developers to work backward from their targeted start date, identifying milestones for life-cycle assessment modeling, feedstock validation, and tax credit registration and compliance.

US, EU Policy Picture 

Meanwhile, policy uncertainty continues to hamper progress. In the U.S., SAF and RD producers are awaiting further guidance on the Section 45Z Clean Fuel Production Tax Credit under the Inflation Reduction Act. Without it, revenue modeling and investment decisions remain speculative. Meanwhile, the expiration of the Section 40B tax credit and uncertainty surrounding the import treatment of feedstocks, such as tallow, further complicate the market.

In the EU, mandates under ReFuelEU Aviation, part of the “Fit for 55” package, require increasing volumes of SAF in aviation fuel starting in 2025, with targets rising steadily to 2050. It is worth noting that in the EU, the amount of UCO feedstock that can contribute to the Renewable Energy Directive is capped at 1.7% in the road transport sector, but it is not capped in aviation fuel mandates. Meanwhile, maritime programs, such as the FuelEU Maritime Regulation, are expected to drive RD demand, but feedstock competition and infrastructure gaps remain. Globally, a unified SAF credit and traceability system is lacking, forcing producers and airlines to juggle multiple compliance frameworks with differing definitions and requirements.

Best Practices to Mitigate Feedstock Risk 

To navigate these challenges, producers should:

  1. Secure long-term feedstock and offtake agreements that align with financing and regulatory requirements and consequences.
  2. Document traceability thoroughly, from origin to final use, using bills of lading, testing data, and compliance certifications.
  3. Engage early with regulators and compliance experts to understand the timing and requirements for fuel pathway approvals and tax credit eligibility. 
  4. Align feedstock selection with regional supply advantages to minimize life-cycle emissions and cost.
  5. Design facilities with flexibility in mind to adjust to future shifts in demand and policy.

Looking Ahead 

The renewable fuel sector is at an inflection point. As SAF and RD projects develop, their long-term success depends on feedstock integrity, traceability, and regulatory foresight. Clarity on tax credits, global policy harmonization, and smarter infrastructure decisions are critical to reducing both operational and capital risk. Developers who treat compliance and traceability not as regulatory hurdles, but rather as strategic investments from the outset, will be best positioned to deliver the low-carbon fuels the world urgently needs.

Author: David Dix 
Account Manager, Low-Carbon Petroleum  
SAF, Renewable Diesel, and Carbon Markets  
Email: ddix@ecoengineers.us 

‘Every Molecule Matters’

The following is an article originally published by Ethanol Producer Magazine on May 13, 2025.

The steps are simple, with low capital and strong ROI: Engage with the appropriate analytics labs to help calculate in-situ cellulosic ethanol production from corn kernel fiber; register those gallons with the appropriate markets; and enjoy the new competitive advantage. McCord Pankonen, ethanol and biodiesel service director with EcoEngineers, says in-situ CKF ethanol is seeing a surge as a result of its accessibility and its advantages over first-generation ethanol in programs such as the Renewable Fuel Standard and California’s Low Carbon Fuel Standard. 

In January and February of 2025 (the most recent data available at press time), 13.6 million D3 RINs were generated for cellulosic/CKF ethanol. For the same months in 2024, approximately 374,000 were generated. 

“What’s neat about the opportunity is ethanol producers really don’t have to do a ton of altering of their plants,” Pankonen says. “It increases revenue for the same kernel that’s going through the process, so really the lift is to get it registered and then engage markets.”

Pankonen also strongly recommends ethanol producers looking into CKF ethanol (also called generation 1.5) partner with the right enzyme provider to maximize value in fiber-degrading packages and strengthen cellulosic production. EcoEngineers, for its part, helps consult, advise, audit programs and train plant staff across a wide area of opportunities, including adherence to cellulosic compliance standards in the RFS and LCFS. 

Certainly, the process to register and continue compliance is complicated, but producers can see significant benefits through the work, he says.

“When we’re in a market calculating carbon intensity, every molecule matters.”

Enzymes: Maximizing Markets  

“One of the first decisions an ethanol producer needs to make is whether they want to maximize the value of their corn kernel fiber or just enter the cellulosic ethanol market,” says Laura Bostic, global marketing manager with Novonesis. 

Novonesis’ trademarked Fiberex portfolio has multiple solutions designed to meet a customer’s specific needs in CKF conversion. “We know ethanol producers’ priorities are diverse and finding the right combination of products to maximize a plant’s value and meet those needs is crucial,” Bostic says. 

“Is the focus generating D3 RINs, participating in state markets like CARB (California Air Resources Board), increasing ethanol and oil yield, or a combination of other drivers?  Essentially, what is the customer hoping to achieve?” she adds. “Novonesis’ fiber-degrading enzymes can help a plant achieve their goals and maximize the value from their corn kernel fiber across all of these areas.”

Fiberex products contain powerful cellulases to generate cellulosic ethanol for D3 RINs or state low-carbon markets, Bostic says. “Hemicellulases work to further break down and hydrolyze the fiber matrix, releasing trapped cellulose, starch and oil. Meaning, in addition to cellulosic ethanol, more glucose is released, giving a bump to starch ethanol, plus a significant increase in extractable oil potential.”

Fiber-degrading enzymes have more complex work to do than a traditional first-generation starch enzyme. Traditional first-generation glucoamylases and proteases do not degrade cellulose or hemicellulose—the main components of corn kernel fiber, Bostic explains. So when a cellulase or hemicellulase is used to break those down, they’re also hydrolyzing the fiber into fermentable sugars the yeast can convert into ethanol. 

“The fiber matrix is a very tightly bound structure, and as the cellulases and hemicellulases are working on that fiber, it loosens it up, which then enables components trapped in that very tight structure to be released,” Bostic says, adding that without cellulase and hemicellulase, that valuable fiber goes out with the wet cake as a waste product.

IFF Staff Scientist Brad Kelemen emphasizes fiber’s complexity as well. “Cellulose is really tough. It’s a recalcitrant substrate so it’s highly insoluble. It’s problematic and requires chemical pretreatment or other treatment to get access to cellulose.” It’s much tougher, he says, than the starch part of the process in terms of the speed of the reaction and the challenges working with it. “The hemicellulose—the fiber—is difficult in that it’s complex. There’s a lot of variety in it and there’s a lot of branching, a lot of cross linking, a lot of different bonds to work on.”

Because of the complexity, a fiber-degrading enzyme package can be more complicated to produce, Kelemen says. “We have a world-class R&D group that understands the application of our enzymes very well in these processes. So I’m very excited about the things to come. But they’re complex, so it takes some time to develop them.” 

IFF also focuses on downstream processes with its fiber-degrading enzymes—Optimash F200, Optimash AX and Optimash Cellulase. “The biggest concern is that these enzymes can have some impact on downstream parts of the process. It’s a concern when working on them to look for suspended solids development because they can start producing greater suspended solids and those will increase the viscosity in the syrup or start fouling the evaporators. So it’s important to develop things that act on the fiber but don’t necessarily exaggerate any downstream effects that might come.”

IFF focuses on dual purposes for its enzyme packages, seeking to maximize the value of other CKF coproducts such as corn oil and other benefits such as cellulosic RINs and LCFS qualification, Kelemen says. “It’s by design that these things are beneficial in multiple places.”

Testing and Analytics  

Neogen has captured interest in the ethanol industry for its work on the in-situ cellulosic ethanol testing and quantifying method that was approved by the EPA in March 2024. Neogen started with a method developed by Justin Sluiter with the National Renewable Energy Laboratory, using it as a “backbone” for its method, according to Matthew Nichols, director of biofuels strategic market for Neogen. 

“Previously, Justin had come up with a method for detecting corn kernel fiber, but a number of challenges remained,” Nichols says. “When you would test a sample pre- and post-fermentation, the post-fermentation would commonly have more fiber than pre-fermentation.

“That doesn’t really make a lot of sense, so we realized that what was happening was the fiber from yeast was being counted as part of the process,” he adds. “We came up with a yeast-degrading cocktail and modified the method on a number of steps, and we were able to eliminate that fiber from the yeast.”

The ASTM approval process, required for EPA approval, is robust, Nichols says. It requires full publishing of the method and unanimous approval by voting members. After several iterations with the ASTM process, the testing method was approved by the EPA and prompted an influx of EPA Efficient Producer Pathway approvals. As of April 2024, a total of 14 ethanol-related operations had approved D3 RIN pathways, according to the EPA. As of April 2025, that number had increased to 117. Not all of these approved D3 RIN pathways, of course, are for CKF.

Nichols points out that the accomplishment was the result of industry-wide collaboration, with input from producers as well as top CKF analytics labs. “The industry came together and worked through some scientific inquiry; we did meet the requirements and we got the method across the finish line, so it has met the EPA specifications and we’re just really happy about everyone working together.” 

The National Corn-to-Ethanol Research Center of Southern Illinois University Edwardsville also has created an in-situ CKF ethanol testing method, though it is not approved for RFS pathways or for California’s LCFS. Yanhong Zhang, interim executive director of NCERC, says it is a VCSB method, but the lab has not sought EPA approval. 

“In my opinion, the reason NCERC’s method was not popular among the industry … was because our method only delivers results to support about 1% ethanol increase for 1.5-generation processing versus some other popular methods will deliver results to support over 3% ethanol increase (for the same fermentation batch),” Zhang says. 

Different analytical methods report varying ethanol yield lifts, Pankonen explains. “There are calculations out there on the content of cellulosic. It’s important to make sure folks are engaging with analytical labs accordingly.”

According to Zhang, NCERC’s method first optimized the total starch testing method by improving the conversion of starch in the corn matrix to glucose. Next, Zhang’s team developed a total cellulosic method based on the NREL cellulose in biomass method, using acid hydrolysis to convert starch, cellulose and yeast cell wall to glucose, then subtracting the glucose from starch to estimate the cellulose level in the sample.

Market Opportunities  

Producers using an approved pathway can generate D3 RINs through the EPA’s Efficient Producer Pathway program. D3 RINs have a value of $2 to $3 more than D6 RINs at any given time, depending on market fluctuations. “When we talk about why ethanol producers really want to look at the benefits for registering for D3 RINs or kernel fiber ethanol, it really boils down to the higher RIN value,” Pankonen says. “It’s worth the opportunity for ethanol producers to register their facilities for D3 RINs. The impact can be pretty significant.”

LCFS, in contrast, is based solely on carbon reduction. CKF ethanol, through the program, has a score 30 points lower than that of first-generation starch ethanol, Pankonen explains. “So, literally, the more carbon reduction you have at your facility, the higher price per metric ton of CO2 produced you would receive,” he says, adding that potential revenue per gallon can range from $1.50 to $3. Assuming a 1% yield lift, a 100 MMgy plant can qualify for a 30-point reduction on 1 million gallons. 

For both RFS and LCFS, producers need to submit a third party-validated pathway and, following approval, conduct quarterly and annual compliance reporting. 

“You have to have a carbon-reduction strategy, and this is something that pays itself back pretty well in terms of return on investment within a year,” Pankonen says.

The Clean Fuel Production tax credit in 45Z is another area where producers can potentially cash in on their carbon-reduction strategies. “45Z is really about making sure you understand what your carbon intensity is first and foremost,” Pankonen says. “I wish that more cellulosic ethanol could qualify that’s inside a kernel of corn, but there’s only so much you can get.” Guidance and supporting frameworks were released in early 2025, but the timeline for implementation of 45Z remains unclear. 

The qualifying threshold, as proposed, for 45Z is 47.4 grams of CO2 equivalent per megajoule. “If you’re at 48 points and cellulosic ethanol can bring your overall volume down, maybe that pushes you into that tier where you can take advantage of 45Z,” he says. 

It’s clear that valuable opportunities are accessible for CKF ethanol, whether through direct monetary benefits or in market access via low carbon-intensity gallons. “It really allows ethanol producers to be more competitive on the gallons they’re processing through the ethanol plant,” Pankonen says.

EcoEngineers – CDR Consultant Interview

The following is an article originally published on the Carbon Unbound website on May 15, 2025. 

Unbound Showcase is a globe-spanning series of interviews with pioneers of carbon dioxide removal (CDR). We’re questioning innovators, business leaders, policymakers, academics, buyers, and investors taking on the challenge of our lifetime – gigaton-scale carbon removal from the Earth’s atmosphere.

Today’s interview is with David LaGreca, Managing Director of Carbon Markets, EcoEngineers

Background

Can you tell me more about your background?

David LaGreca –

My background is primarily in the voluntary carbon market (VCM), where I’ve spent the past eight years. I’ve worked as a validator and verifier on various CDR projects across the Western Hemisphere, covering most voluntary registries. These projects have ranged from mangroves and direct air capture (DAC) to landfill gas and oil and gas. The CDR market has provided me with opportunities to travel and explore diverse methods of decarbonization. Having conducted more than 100 audits in my previous roles, I’ve gained valuable insights that have helped me consult effectively and avoid pitfalls in creating viable businesses based on novel CDR technologies, despite the high degree of uncertainty. As an avid outdoors person, growing up hiking and mountaineering with my family in the Rocky Mountains, I believe that has defined my purpose and drawn me towards a career in which I can help preserve those places that may be impacted by climate change.

Who is EcoEngineers, and what was the inspiration that led to its creation?

David LaGreca –

EcoEngineers is a consulting, auditing, and advisory firm recently acquired by leading global assurance partner LRQA with an exclusive focus on the energy transition and decarbonization. LRQA provides clients with deep expertise in assessment, advisory, inspection, and cybersecurity services. Operating in more than 150 countries with a team of more than 5,000 people, LRQA’s award-winning compliance, supply chain, cybersecurity, and ESG specialists help more than 61,000 clients across almost every sector to anticipate, mitigate, and manage risk wherever they operate.

EcoEngineers ventured into the VCM due to its increasing adjacency to regulated and compliance markets. Recognizing the need for VCM services, the company expanded its offerings to include CDR services and developed many of the first CDR methodologies. The company’s extensive knowledge in science, methodologies, markets, and audits has led us to be leading advisors in the CDR sector.

Inspiration

What led you to your current role at EcoEngineers, and how does your professional work align with your personal beliefs and values of reducing the effects of climate change?

David LaGreca –

Coming from the world of audit, I recognized the potential for companies needing skilled advice to get their CDR projects off the ground. There is an exceptional opportunity to utilize fresh concepts in decarbonization, and the only way I could make that happen is through advisory services. When EcoEngineers approached me for a job, I pitched the VCM program and have since leveraged their exceptional in-house expertise to grow an outstanding team.

CDR Technologies

What role do you see in novel, hybrid CDR technologies and techniques like direct air capture (DAC) with afforestation, biomass with carbon capture and storage (BECCS), or ocean-based CDR with enhanced weathering in achieving net-zero emission goals?

David LaGreca –

We have done consulting work on a wide range of CDR technologies. Each of these technologies is just one of the pathways to undo all the damage caused by the effects of climate change. We have to focus on driving down emissions today in industrial sectors, but these promising solutions will only help bring us back to where we used to be. That’s why we need all the tools in the CDR toolkit. DAC, along with afforestation, BECCS, and soils-based approaches, like enhanced weathering, each tackle the problem differently, in different environments, with different and unique strengths. No single solution is going to cut it. The challenge is too big and too urgent to put our eggs in one basket.

Importance of MRV

Given that data is paramount for monitoring, reporting, and verification (MRV), how is EcoEngineers supporting clients in ensuring the integrity and transparency of their data when quantifying the carbon footprint of CDR projects?

David LaGreca –

Carbon markets only succeed when the data is verifiable—that means the data must back up the claims. We take a risk-based approach to developing our crediting methodologies and the compliance documents for carbon credits and align those approaches with an understanding of the science that we glean for each project. This knowledge is utilized to confirm that the stated values are in no way misrepresented. The mix of people on our team is what makes this possible, ranging from Ph.D.s, geophysicists, scientists, and practitioners in life-cycle analysis (LCA), and Intergovernmental Panel on Climate Change (IPCC) experts in energy and land management. We possess a wide spectrum of in-house expertise in how CDR systems interact with the mechanisms of the markets. Given that our clients know more about their businesses than we do, in many cases, we leverage their understanding of their unique processes to build a viable and verifiable framework for carbon crediting.

Carbon Credit Impacts

How can organizations effectively navigate the complexity of selecting high-quality carbon credits for their sustainability or net-zero goals?

David LaGreca –

It’s important to work with reputable, high-integrity third parties. In particular, you have to ensure that credits and projects are reviewed by competent auditors. With competent auditing comes trust in the integrity of credits; buyers then enter the market with a high degree of confidence. Building confidence in carbon credits has morphed into a process involving more than just a single validation body and now includes multiple levels of diligence for many companies in carbon credit purchases. What it comes down to is finding a level of comfort that the claim can be supported by the project. This does not need to be a 12-step process and could be refined by re-establishing the prominence of diligent MRV in the methodology and project verification phases.

In all the CDR projects that come through us, we try to bring certainty that the projects fill the gaps between science and the markets. We use our experience to implement best practices for all aspects of project design. For novel project categories that don’t yet have established best practices, we apply our overarching industry knowledge and rigorous standards to develop high-integrity methodologies.

About the Expert

David LaGreca is the Managing Director of Carbon Markets at EcoEngineers, with expertise in all major 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.

For more information about how EcoEngineers can help you navigate the CDR market and set your company or organization up for success, contact: 

David LaGreca, Managing Director, VCM | dlagreca@ecoengineers.us

About EcoEngineers

EcoEngineers, an LRQA company, is a consulting, auditing, and advisory firm with an exclusive focus on 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.

Cowboy Clean Fuels’ New Methodology Combines CDR With Renewable Energy

The following is an article originally published in Carbon Herald on April 28, 2025.

Cowboy Clean Fuels (CCF), a Denver-based company specializing in renewable energy and CO2 technology, has released a new methodology that combines Biomass Carbon Removal and Storage (BiCRS) with Renewable Natural Gas (RNG).

The novel BiCRS+RNG methodology was developed in a collaborative effort with EcoEngineers, a clean energy consulting, auditing, and advisory company recently acquired by leading global assurance partner LRQA.

As part of the collaboration, Eco made sure that the BiCRS+RNG methodology follows the highest scientific rigor, sustainability, and transparency standards, assuring project developers that by adopting this methodology, they will be in compliance with ISO 14064-2:2019.

What the methodology specifically provides is an innovative, industry-first framework that outlines a strict approach for measuring and monitoring, reporting, and verifying (MRV) an innovative decarbonization technology that brings together biogenic methane production with permanent geologic carbon sequestration utilizing legacy energy infrastructure.

BiCRS represents a technology in which carbon-rich biomass is stored underground, keeping it from decomposing and releasing CO2 back into the atmosphere. 

Springing from a proprietary CCF process, the BiCRS+RNG methodology lays out an approach for injecting biomass-derived feedstocks into geologic formations, where it triggers the microbial conversion to carbon and biomethane. 

This process also enables the surface production of biomethane, which can then be delivered to end users as a low-carbon renewable natural gas (RNG).

Through a durable adsorption process, this approach offers a pathway for permanent geologic CO2 sequestration that presents a long-term, scalable carbon solution. 

By aligning carbon removal projects with the highest industry standards, the BiCRS+RNG methodology developed by CCF provides a verifiable pathway for generating high-integrity carbon removal credits, presenting a market gateway for project developers. 

Ryan Waddington, chairman and CEO of Cowboy Clean Fuels, said that the completion of the BiCRS+RNG methodology “represents a major milestone in the evolution of engineered carbon removal and renewable energy production.”

He added, “This methodology enables shovel-ready projects to move forward with confidence, allowing our capital partners to invest with certainty in the Powder River Basin and beyond.”

Optimizing Biogas Revenue At Codigestion Facilities

The following is an article originally published in Biocycle on April 15, 2025.

By Brad Pleima

The U.S. Environmental Protection Agency’s (USEPA) Renewable Fuel Standard (RFS) 2023-2025 Set Rule, released in June 2023, introduced significant opportunities for the renewable natural gas (RNG) and biogas industries. Included in the rule were provisions specific to RNG, referred to as the Biogas Regulatory Reform Rule (BRRR). By allowing the codigestion of feedstocks to generate both D3 and D5 Renewable Identification Numbers (RINs), the rule offers a path to enhanced revenue streams for RNG projects. However, capitalizing on these opportunities requires strategic planning and operational readiness.

A Shift in RIN Calculations

Codigestion refers to the process in which multiple organic feedstocks, such as dairy manure (classified as a D3 feedstock under the RFS) and food waste (classified as a D5 feedstock), are processed together in a single anaerobic digester (AD) to produce biogas. Previously, facilities codigesting non-cellulosic material faced limitations — RNG derived from codigested D3 and D5-eligible feedstocks would default to the lower D5 RIN category.

The RFS Set Rule, however, allows for allocating D3 and D5 RINs based on the cellulosic converted fraction (CCF), a calculated measure of the amount of biogas produced from a D3-eligible feedstock. This fraction is critical, as it determines how much of the generated gas can be attributed to each feedstock type, thereby unlocking the potential for higher revenue streams through higher value D3 RIN generation. Tables 1 and 2 illustrate the revenue benefits gained from utilizing the RFS Set Rule for codigestion projects.

The RFS Set Rule allows two methods for calculating the D3-D5 split: a literature-based approach and a site-specific method:

  • Literature-Based Approach: This method uses conservative biogas conversion estimates provided by the USEPA. It relies on predetermined values for the CCF of various feedstocks, such as swine manure, bovine manure, chicken manure, and municipal wastewater treatment biosolids. These values are linked to specific operational conditions, such as a minimum temperature of 95°F and hydraulic and solids retention time exceeding 20 days.
  • Site-Specific Method: This approach allows facilities to establish a custom conversion factor based on historical data and precise measurements of the digester’s operating conditions, including temperature, pressure, and residence time. The resulting CCF is applicable only if the digester operates within these measured parameters.

For facilities with established baselines, the site-specific method can retain up to 90% to 100% of the D3 RIN value, offering a significant advantage over the conservative literature approach, which may only capture 50% of the D3 RIN value.

At this time, there is not a detailed methodology for how to comply with USEPA’s new split methodologies, especially on the facility-specific path. The exact compliance requirements are not known and the industry will learn more as USEPA considers more of these pathways. EcoEngineers, a consulting, auditing, and advisory firm experienced in the biogas RNG space, expects that facilities participating in the USEPA’s RFS Quality Assurance Program (QAP) will have site-specific protocols approved by USEPA to detail future compliance requirements. Established in 2014, the QAP provides a means for ensuring that RINs are properly generated through audits of renewable fuel production conducted by independent third parties. It is a voluntary audit program, but participation is required for AD facilities to get the full value out of a D3 or D5 RIN.

Implementation Considerations

Transitioning to codigestion requires a thorough assessment of biogas and RNG facility capabilities and economic feasibility. Facilities must evaluate their digesters to determine if they can handle diverse feedstocks without compromising efficiency. Essential components include blending tanks for material preparation, adequate mixing systems to maintain digester performance, measurement devices for tracking each feedstock, solids separation or storage infrastructure, and RNG upgrading infrastructure to process the additional biogas generated.

Additionally, digestate management becomes more complex when non-cellulosic materials are introduced. Facilities must account for changes in volume and composition, which could impact disposal methods. For example, dairy farms accustomed to land-applying manure may find new challenges when dealing with a food waste-derived digestate.

Steps for Codigestion Success

  1. Evaluate and Secure Feedstock: Access to consistent and appropriate feedstocks is the first critical step. Without a reliable feedstock supply, projects cannot proceed. For example, a dairy farm might want to partner with local food processing plants to secure a steady supply of food waste, ensuring a continuous feedstock stream for codigestion. Determining potential codigestion feedstocks and biogas potential is a key first step. Importantly, the feedstocks must meet the regulatory definition of “renewable biomass” under the RFS to qualify for D5 RINs. While not all feedstocks are considered equal, “food waste” generally takes a broad meaning under the RFS.
  2. Assess Facility Readiness: Conduct a feasibility analysis to evaluate infrastructure, including blending and digestate management systems, and determine whether upgrades are needed. For instance, a wastewater treatment plant (WWTP) might need to install additional blending tanks and mixing systems to handle the increased volume and diversity of feedstocks.
  3. Evaluate Revenue Potential: Analyze the economic benefits of codigestion. This involves calculating potential increases in biogas production and revenue from RINs or voluntary markets.
  4. Navigate USEPA Approval: Facilities must obtain USEPA approval for their chosen RIN calculation methodology. While the process is outlined in the regulation, no projects have completed this pathway yet, although several are underway, making it essential to work with experts to navigate uncharted territory. To ensure compliance with the RFS program, facilities must also complete a RFS Engineering Review to obtain a revised RFS pathway. They may also want to consider participating in the USEPA’s QAP to verify that the RINs they are generating are valid.
  5. Monitor Market Opportunities: Beyond D3 and D5 RINs, facilities can explore voluntary markets where biogas from codigestion can often command a higher value. For instance, a producer might consider selling its RNG to companies looking to offset their carbon footprint, thereby accessing premium prices in the voluntary carbon market compared to generating lower value D5 RINs.

Who Benefits?

One of the primary economic benefits of codigestion is the increased energy production potential. By adding energy-rich organic waste materials such as fats, oils, and grease (FOG) and food scraps to dairy or wastewater treatment plant digesters, facilities can boost biogas production. Many of these high energy materials can have three to five times the methane production potential of biosolids and manure, leading to higher biogas yields and, consequently, more revenue. Additionally, codigestion can provide economic benefits through potential revenue from tipping fees for accepting food waste.

The use of existing infrastructure for codigestion also contributes to cost savings. Facilities that already have ADs can utilize their excess capacity to process additional feedstocks without the need for significant capital investment in new equipment. This makes codigestion a cost-effective solution for enhancing biogas production and revenue generation and provides a home for problematic feedstocks such as FOG, which clog public sewer lines.

Long-Term Outlook

While the immediate road to implementation may be challenging, the long-term future of RNG and biogas looks promising. In the short term, the biogas industry will need to stay vigilant and proactive in addressing potential regulatory and policy shifts that could impact their business. The industry is navigating a transitional phase due to changing regulations and new markets as biogas/RNG becomes more mainstream. But the 10-to-20-year outlook suggests a smoother path ahead as advancements in technology unlock new potential.

Emerging technologies such as carbon capture and storage (CCS) and smart grids/solar integration are expected to enhance the efficiency and sustainability of biogas projects. This can lead to a lower carbon intensity score, increased production, and lower cost of delivery, among other benefits. The USEPA’s RFS Set Rule is also a step in the right direction for maximizing the value of biogas, whether used for RNG, renewable electricity, low-carbon hydrogen, or sustainable aviation fuel (SAF).

A Call to Action

For biogas and RNG operators, the message is clear: analyze your options. By conducting a thorough feasibility study and assessing operational readiness, you can determine whether codigestion aligns with your goals. Collaborating with industry experts and stakeholders can provide valuable insights into the risks and rewards of this opportunity, ensuring that you have the data to make informed decisions.

For example, the American Biogas Council (ABC) provides resources to help project developers and operators navigate the complexities of biogas production and utilization. Additionally, collaborating with regulatory consultants and leveraging tools like the Biogas Carbon Accounting Tool (CAT) can help facilities optimize their carbon accounting practices and maximize the benefits of their biogas projects.

With the USEPA’s RFS Set Rule in effect, it is timely to maximize the benefits of feedstock codigestion to monetize the full potential of both D5 and D3 RIN values. By taking proactive steps, biogas and RNG facilities can position themselves to capture additional revenue and contribute to a more sustainable energy future.

Brad Pleima is the President of EcoEngineers, a consulting, auditing, and advisory firm recently acquired by leading global assurance partner LRQA. He has more than 20 years of experience in the renewable energy and engineering sectors, working with municipalities, project developers, and investors on anaerobic digestion, biogas utilization assessments, and biogas upgrading projects, and advising clients on global climate regulations, emerging incentive programs, new technologies, evolving carbon markets, data standards, energy credit markets, commodity markets, feedstocks, and carbon accounting rules.

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

The following is an article originally published by Carbon Herald on March 31, 2025.

This interview has been edited for brevity and clarity. 

Carbon dioxide removal (CDR) is one of the climate action pillars capable of delivering meaningful results towards global net-zero goals. Paired with CO2 emissions reductions, CDR is a tool that’s increasingly sought after by companies, organizations, and governments as a vital part of sustainability plans. 

Last year, the CDR market experienced an increase in both purchases and deliveries, and the trend of growing carbon removal investments seems to follow into 2025, with relevant industry experts projecting further growth in the future. 

While the interest for CDR is on the rise, experts warn that the current carbon removal levels are still falling behind the benchmarks needed to reach climate targets on time and the CDR sector is in need of rapid scaling to tackle the ongoing environmental crisis.

As the focus of CDR buyers switches from investing in the most affordable projects towards backing high-quality, durable solutions, carbon removal integrity and effectiveness emerge among the top priorities driving carbon removal purchases. 

To ease suppliers with the task of verifying their activity against high-quality standards and generating trustworthy CO2 removal credits, clean energy consulting, auditing, and advisory firm EcoEngineers has put together a paper offering guidance on the auditing process. 

Recently acquired by leading assessment and certification specialist LRQA and accredited by the American National Standards Institute (ANSI) National Accreditation Board (ANAB), EcoEngineers is a US-based company that also boasts established capabilities in the EU market, where it partners with auditing teams following regional rules and regulations.

Authored by Roxby Hartley, PhD, climate risk director at EcoEngineers, the paper titled “Five Requirements for High-Quality CDR Audit” outlines the main areas of focus for performing credible CDR verifications.

The five building blocks of the suggested framework include understanding the audit hierarchy, aligning assurance levels with claims, embracing the dynamic nature of audits, choosing competent auditors, and promoting transparency.

This practical approach stems from years of robust experience in guiding CDR projects to meet the highest standards of integrity and transparency. Following these steps with optimal accuracy enables carbon removal suppliers to confidently audit and verify projects in accordance with rigorous market standards.

In a recent interview with Carbon Herald, Dr. Roxby Hartley shared more about the paper and the intricacies of auditing CDR projects. You will find our conversation below.

Can you tell us more about the paper? It stems from EcoEngineers’ vast experience with its client base, right? 

That’s correct. EcoEngineers started as an audit company, and we have been auditors for the U.S. Environmental Protection Agency (EPA) for over 15 years. We audited around a quarter of all the Low Carbon Fuel Standard (LCFS) pathways in California. So we’ve got a lot of experience on the compliance side.

Recently, we’ve been exploring the new carbon removal space. We see that there are many brilliant people bringing great ideas to life. However, they lack experience in auditing.

An audit is a specific process for verifying claims, and we felt that we needed to provide guidance on how to approach it effectively. This is how you should go about it, and these are the common mistakes to avoid. 

Do you mind walking us through the five requirements for high-quality CDR audits? 

Firstly, many organizations’ project leaders will come to us and ask us to check their systems to ensure that what’s being done is correct, and at a very basic level, it isn’t. 

A specific hierarchy is being developed about how you should document what you’re doing.

At the highest level of the hierarchy, we have the ISO standard, the international standard. We have registries that have interpreted specific ISO standards to develop their own standards. These standards might include more or less sustainability requirements, but they’re typically based on ISO. 

Next, you do is design a methodology. A methodology lays out what you should do in a project to generate carbon credits. If you tick all the boxes, you can get carbon credits. 

Once a project aligns with the hierarchy, adheres to the methodology, and complies with the ISO standard, the next step is to have it verified. This process occurs before you generate any credits, ensuring that your project satisfies all the requirements of the methodology and that the methodology fulfills all the necessary standards.

Relevant: LRQA Acquires EcoEngineers, Expanding Low-Carbon Expertise

And then, right at the very end of this, you have the verification of credits, where you say, for example, “We’ve generated 400,000 metric tons of credits over the last year, and we would like that to be audited.” So you invite an independent third party to come in and make sure that the claim is correct.

All categories of claims are made against a document that outlines the boxes you must tick to ensure you can make the claims. That’s your audit hierarchy. We do not audit in a vacuum. We always audit against something that tells us whether they’re doing something correctly. 

The paper also points out the importance of transparency. What steps should CDR suppliers take to ensure everything’s transparent?

That’s actually quite a sticky problem in many situations.

The registries often have very high transparency requirements, which is beneficial because it facilitates a high-quality audit by providing access to all the information. It also means that you’re presenting a wealth of interesting data regarding these novel processes. Furthermore, there is ample opportunity for analysis to enhance the methodology. 

We can enhance our understanding of science by examining all the data available to everyone. Any scientist can come along and analyze the data, suggesting improvements for the scientific processes. The challenge arises when the project proponent, typically the individual undertaking this valuable work, depends on external sources for information.

One classic example in the fuel space is used cooking oil or UCO, which a fuel plant uses to make fuel. If the people supplying that used cooking oil are reluctant to share their information, we can’t pass an audit. 

You need a trusted auditor who will be transparent with all the parties. Still, there are cases where you won’t have a lot of information, and often, it’s because a fuel producer will also be competing against a UCO collector and buying from them at the same time. The UCO collector doesn’t want to disclose all their used cooking oil sources to somebody who could just call the restaurants themselves.

When writing supply contracts, you should include language to ensure your auditor can review all your data to get reasonable or limited assurance that what you say you’re doing, you’re actually doing. Or you’ll apply a penalty if you do not allow the auditor to review that information. If not, you’ll fail your audit, or you will probably have a finding against you that you can’t mitigate.

Are there roadblocks that suppliers should be prepared for when trying to go through the auditing framework? 

There might be gaps. This is why we talk about auditor competence. Auditors usually rely on a clear list of instructions with boxes that need to be ticked off, making sure everything meets the methodology requirements or the credit generation requirements.

The problem comes when the methodologies are new.

For example, the California Air Resources Board’s LCFS regulation could be considered analogous to a methodology. It has very detailed instructions and is backed up by a large staff that interprets those instructions for new projects.

So you bring a project to the California Air Resources Board, and they will go through it in detail to ensure it fits the regulation. When a project comes along that has a novel process, CARB builds specific operating conditions into the project so that it meets the regulation.

The methodology lacks information and, in some cases, expertise. California has a large staff of very experienced modelers who understand greenhouse gas emissions. Still, this expertise is sometimes not available, or the methodology writers fail to recognize that best management practices must be used, which are not reflected in the project. Consequently, skilled auditors must point out that this isn’t correctly written; this project must have the following operating conditions that have not been implemented. That’s where the project is at the validation stage. If you go through a process, can this meet the methodology? Yes. 

It could be as simple as a transportation emissions model that is overlooked. There are numerous transportation emission models, but you might select one that isn’t pertinent to your project, or you might decide on a method that renders it unusable for your project. A classic example is if I’m managing a fleet of trucks, it’s very easy to calculate my emissions because I know how much fuel I’m purchasing. For all the fuel used in the fleet of trucks, I can account for the fuel that goes into the fleet.

I’m taking this into account, and these go from A to B, but that doesn’t capture all the fuel used in that transportation.

However, it is important to consider all surrounding factors, and it is advisable to use an average emissions model rather than a model solely based on direct fuel-related emissions. This reflects an understanding of the life cycle assessment (LCA) modeling. It’s very tricky and sticky. EcoEngineers has ten Ph.D.s on staff in LCA modeling who are excellent at pointing out mistakes like these. An experienced modelers is essential to building out an LCA model. 

EcoEngineers is one of the accredited Validation and Verification Bodies by the American National Standards Institute (ANSI) National Accreditation Board (ANAB). Can you tell us more about the significance of this accreditation?

ANAB is an auditor of auditors. It requires us to have very high documentation standards internally and training of all our auditors. We are audited on our audit process by them.

There’s a particular process you go through with an audit. You take the document and do a risk analysis, which is verification. You say, “Of all the things I’m going to be looking at in your project, which are the ones that can go wrong, and which ones will have the most impact?” And it could easily go wrong, and it will have a huge impact. I want to ensure that all the data is right.

For instance, when there are a hundred farms supplying biomass to this project and I have bills of lading demonstrating their activities, they maintain a good documentation trail, providing me with reasonable assurance. I might choose to visit one farm out of the hundred, but I’m not going to visit all of them, so my sample size remains small. However, if I go to that farm and discover that what they claim to be doing is incorrect, then I would expand the sample size. Thus, we follow a very structured process, and ANAB comes in to verify each step we’ve taken.  We conduct an internal review, and also occasionally, we’ll be audited to make sure that our audit process, our documentation, and what we’re recording about the audit are correctly laid out.

What specific services does EcoEngineers offer to suppliers? 

We offer all services on the audit side. This includes California’s LCFS, Canada’s CFR, Oregon CFP, 45V, M-RETS, as well as custom audits, MRV protocol creation, agricultural emissions verifications, Isometric, Puro.earth, Green-e, and Scope 1, 2, & 3 emissions reporting verification. We do a lot of quality assurance protocol (QAP) audits, which is a program for the EPA. We offer a wide range of services, and we can offer validation services, which include checking over projects before they generate credits or checking over methodologies before they’re accepted to a registry. 

And then, we can do the verification audit for carbon credits at the end on the audit side.

On the consulting side, we can write all those documents in preparation for the audit. We write methodologies for clients, and we write project plans for clients against methodologies. We feel like we do a really good job at helping people come to market with their carbon credits.

Besides improved auditing, what else needs to happen to catalyze the development of the CDR sector?

Some market trends are occurring right now. If you visit the EPA website for class VI wells, there are, I believe, 20 class VI wells that will become operational over the next two years. 

This is in the US, and that doesn’t include North Dakota, Louisiana, or Wyoming. Those wells can store 100 million metric tons of carbon each. In the next two years, two gigatons of carbon storage will come online in the US. 

If you look at the amount of storage coming online, all those storage companies are going to be competing for carbon dioxide. They want the projects to go forward and profit because they’ve put a lot of capital into developing them. And so there will be many people trying to sell CO2 because the 45Q tax credit means it’s pretty lucrative to store CO2.

I suspect that storage will start, and the oversupply of storage will drive carbon capture, particularly in the southeast of the US, both in the CDR and in the avoidance markets.

Read more: DOE Considering Funding Cuts For The Two Largest DAC Projects In The US

There are also some in California. Elk Hills, California Resource Corporation, is going forward with its big capture project in Southern California. A lot of storage is coming online, and people will match it with capture. 

This development of carbon capture at point sources is also going to help all the CDR companies that are looking for direct air capture (DAC), which removes CO₂ from the air and then stores or reuses it, and other technologies where they’re capturing CO2 and putting it underground.

They’ll find that storage is very cheap and easily available. The problem we have with, say, DAC is where to get the energy. These are highly energy-intensive programs, and they won’t work with grid emissions.

If you look at the carbon intensity of the grid emissions per kilowatt-hour, you won’t be able to make those projects carbon negative.

So, you have to find sources of renewable energy, such as solar and wind energy. But all those solar and wind power projects are going forward anyway.

How Urban Centers Can Identify and Mitigate GHG Emission Hotspots Within City Services

The following is an article originally published on Energy Central on March 17, 2025.

Urban centers across the United States (U.S.) face increasing pressure to curb greenhouse gas (GHG) emissions from public services such as transportation, waste management, and utilities. While many municipalities are waiting for future technologies like clean hydrogen and electric vehicles (EVs) to scale, practical solutions exist today that can significantly reduce emissions. By identifying GHG emission hotspots and implementing proven strategies, municipalities can adhere to existing or new climate action plans (CAPs), enhance resilience, and demonstrate leadership in sustainability.

Identifying and Assessing GHG Hotspots

The first step in reducing GHG emissions is to assess what can be quantifiably tracked and measured within the service departments. This does not include supply chain management, which focuses on the production and distribution of goods beyond city service control. GHG inventories can also be a useful tool for quantifying GHG emissions at the municipal operations and community-wide scale. Once a CAP sets an overarching GHG reduction target aligned with the inventory, more detailed GHG quantification can then occur at the project level for planning and implementation. 

Common areas for identifying and evaluating GHG hotspots include:

  1. Transportation 
    Fleet emissions are often among the largest contributors to GHG emissions. Traditional diesel and gasoline vehicles are a significant source of GHG emissions from public transportation systems and waste management, street departments, emergency services, and others. Additionally, fuel costs are often unpredictable and have grown significantly over the past several decades.
  2. Waste Production 
    Landfills and waste management systems release significant GHG emissions. Studies from the U.S. Environmental Protection Agency (USEPA) have recognized these sources contribute to urban pollution and are likely to become more heavily regulated and monitored for compliance.[1]
  3. Energy Use
    Energy delivered to cities throughout the U.S. generally is delivered and managed by complex infrastructure that is expensive and challenging to replace and expand. Utilizing existing natural gas, electric, and steam infrastructure fueled by renewable sources effectively reduces these emissions without significant capital investment. Technologies such as Geographic Information Systems (GIS) and data analytics tools can be employed to visualize GHG emissions and identify emission-intensive sources. This process enables cities to create detailed maps of their city services, pinpointing specific suppliers, transportation routes, or operational sources that require targeted interventions. Key indicators to focus on include energy consumption, waste production, and transportation emissions.

Proven Technologies and Programs for Immediate Action

Urban centers and municipalities can implement various solutions to reduce the environmental impact of city services, including:

  1. Transition to Renewable Energy Sources
    • Encourage fuel suppliers to switch to renewable fuels such as renewable natural gas (RNG) to power fleets or utilities.
    • Leverage waste-to-energy programs to integrate municipal waste management with traditional energy generation.
  2. Optimize Transportation Routes
    • Use low-emission vehicles, such as electric trucks or RNG-powered fleets, and streamline logistics to reduce transportation emissions.
  3. Waste Minimization and Recycling
    • Promote circular economy practices and implement zero-waste programs to reduce emissions from waste production.

Case Studies: Municipalities Leading the Way

Several cities across the U.S. have successfully implemented these strategies, demonstrating their feasibility and benefits.

  • Des Moines, IA: Des Moines has effectively integrated waste management with energy generation by expanding its waste-to-energy facilities. The Des Moines Metro Methane Recovery Facility at the Metro Park East landfill captures landfill gas, primarily methane, and converts it into electricity. An expansion completed in 2013 increased the plant’s energy capacity from 6.4 megawatts (MW) to 11.2 MW, supplying clean electricity to approximately 11,200 homes.[2]
  • Dallas, TX: Dallas has taken concrete steps toward emission reductions through energy optimization as part of its Comprehensive Environmental and Climate Action Plan. The city is committed to reducing GHG emissions by 50% and improving energy efficiency by 20% across its portfolio of 140 facilities over the next 10 years. Strategies include maximizing energy efficiency, decarbonizing buildings, transitioning fleets to electric and low- or no-carbon fuels, and installing renewable energy systems and other innovative technologies across its facilities.[3]
  • Sioux City, IA: Sioux City has adopted innovative approaches to reduce emissions through its Renewable Fuels Project at its Wastewater Treatment Plant. The facility recovers methane and carbon dioxide (CO2) produced through wastewater treatment and converts it into RNG. This RNG is then used as vehicle fuel, creating new revenue streams, and supporting the city’s vision for a healthier environment.[4]

These examples highlight the immediate economic and environmental benefits municipalities can achieve by adopting proven solutions. Additionally, CAPs can help guide these efforts by identifying cost-saving and revenue-generating opportunities through energy efficiency and production, ultimately contributing to their long-term financial sustainability in the most cost-effective way possible.

Municipalities can choose between self-managed programs or outsourced solutions, with both options offering flexibility and financial benefits. Transforming emission-heavy operations into revenue-enhancing programs is a viable and sustainable approach.

Long-Term Climate Goals: Bridging the Gap

Immediate actions taken today can lay the groundwork for achieving 2050 net-zero targets. By implementing available technologies, urban centers can avoid the pitfalls of waiting for unproven solutions. The steps and case studies described above not only ensure measurable progress today but they also provide a strong foundation for achieving long-term climate strategies.

Urban centers must act now to identify and mitigate GHG emission hotspots within their city services. Proven technologies and strategies are readily available such as RNG or electrification, enabling cities to achieve both environmental and financial benefits. Municipalities are encouraged to implement these solutions today, setting the stage for achieving their net-zero and climate action goals. 

About the Expert

Dave Lindenmuth is the managing director of RNG services at EcoEngineers. With over 20 years of experience in the energy industry, he specializes in renewable project development, business strategy, and compliance readiness. For more information, contact Mr. Lindenmuth at dlindenmuth@ecoengineers.us. 

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