The U.S. biogas industry is enduring a period of change at the moment. Amid efforts from congress and the U.S. EPA to reduce greenhouse gas emissions and boost the nation’s RNG production, the industry has been faced with a constantly shifting legislative landscape over the course of the past year. The major overarching development in this regard is the Renewable Fuel Standard, which aims to establish guidelines surrounding the annual volume of renewable fuels that are blended with traditional petroleum-based fuels for transportation. These targets aim to grow the industry as a whole, with the added benefit of reducing national reliance on imported oil.

While these reforms paint a bright picture for the sector’s future, their success depends upon the implementation of tighter regulation from the ground up. Central to this are renewable identification numbers (RINs), which can be thought of as the currency of the RFS program. Each physical gallon of RNG produced is assigned a unique RIN, which travels with the batch of fuel between parties when traded, though the two can also be separated in order to be sold independently of one another. Understandably, the entire system hinges on RINs not being logged or counted incorrectly, which many industry stakeholders have highlighted as a potential issue.

A Double-Edged Sword
It is for this very reason that an adjacent piece of legislation, the Biogas Regulatory Reform Rule, has been introduced, aiming to strictly regulate RNG production via new limitations on the equipment that can be used for measurement. While this is intended to improve the accuracy in the generation and tracking of RINs, it is important to also acknowledge the impact that this will have on day-to-day productivity for RNG producers.

Under the BRRR, the EPA previously ruled that only gas chromatographs would be able to be used for measurement during RNG production. However, this offers up a series of challenges, especially given that the vast majority of the industry is already using gas analyzers for the very same task. Gas chromatographs, while highly accurate, are more traditionally associated with the laboratory environment, rather than that of an active biogas plant. As a direct result, they are in scarcer supply, with a much higher point of purchase. Should the entire industry transition to gas chromatographs as required by the BRRR, there would likely be significant effects for the continuity of RNG supply.

Exploring the Alternatives
Fortunately, this is an issue that the EPA has again listened to industry stakeholders about, with the alternative measurement protocol, (AMP), introduced as a solution. Under the AMP, original equipment manufacturers such as QED Environmental Systems are able to submit equivalent technology for use in place of a gas chromatograph, which will be reviewed by the EPA on a case-by-case basis.

Critically, this allows biogas producers to continue using gas analyzers as the instrument of choice for measurement. Versus a gas chromatograph, these units offer a specialized design for biogas production and the outdoor environment, and can achieve the same highly accurate results as a gas chromatograph in a fraction of the response time, while also being easier to operate. Perhaps most importantly, gas analyzers benefit from a well-established install base already in operation, meaning that an industrywide switchover would not be necessary.

Forging a Credible Path
While final approval on these instruments is pending, the EPA recently indicated that facilities with completed registrations proposing to use equipment covered by the AMP can proceed with provisional approval. Here, RNG producers need only register their facility using the original equipment manufacturer’s unique number to be eligible for provisional approval. For example, QED Environmental Systems’ EPA registration number, JSDEP-25477, will allow RNG producers to use the Biogas 3000 and Biomethane 3000 for the generation of RINs while full AMP approval is pending.

In this sense, the AMP allows RNG producers to continue down their current path and ensure minimal disruption to production, without need for equipment changeover. Here, the AMP is a landmark development for the industry in that it will allow biogas producers to reap the benefits of the RFS without impacting the continuity of supply. With this legislation in place, it is our hope that the industry can continue to grow and cement the U.S. as a world leader in RNG production.

Author: James Jones
Gas Instruments Product Manager, QED
www.qedenv.com

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