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

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

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

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

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

For more information please contact clientservices@ecoengineers.us.