Given the importance of regulatory programs and tax incentives to the economic viability of industry projects, standardized biogenic testing is critical to the success, as well as the emissions reduction goals to which they are contributing.
By Benjamin Kling
As the world scrambles to meet emissions reduction goals on the path to net-zero, governments are increasingly relying on regulatory programs and tax incentives to promote, track and validate emissions reductions. One important path to achieving emissions reduction is the use of biogenic feedstocks, meaning material derived from biomass, to replace the use of fossil derived content. However, it can often be difficult to quantify the amount of biogenic content of heterogeneous emissions and waste without testing directly.
As a result, a critical tool for these regulatory programs has been the ability to measure the renewable portion of emissions and waste using Carbon-14 testing via standards such as ASTM D6866 and ISO 13833 in order to incentivize the portion of these emissions and waste contributing directly to decarbonization.
What is Biogenic Testing?
Biogenic content testing uses carbon-14 analysis since the carbon-14 isotope is present in all living organisms. Petrochemical-derived material no longer contains any carbon-14 content due to its age as carbon-14 is lost over time via radioactive decay. Results are reported as a percentage of biogenic content which reflects the portion of the material produced from renewable feedstocks.1
The most widely used international standard for biogenic content testing is ASTM D6866. Other similar standards created for specific applications, such as EN ISO 13833 which specifically measures the biogenic content of stationary source emissions, are more commonly used in European programs.2 The use of widely recognized scientific standards has been critical to the early success of regulatory programs designed for biofuels because they allow the governing body to verify claims and accurately assess progress.
What are the Industry Applications for Biogenic Testing?
Flue Gas Emissions
One relevant industry application of biogenic content testing is the direct measurement of flue gas emissions. This is due to the importance of biogenic testing for emissions reporting and cap and trade programs regulating large industrial emitters. By allowing regulated entities to directly test their flue gas for biogenic content, these measurements are convenient for producers to obtain and provide regulators with critical information on their emissions reductions.
Regulatory programs focused on emissions reductions that require direct biogenic testing of flue gas emissions from industrial facilities include the U.S. EPA’s Greenhouse Gas Reporting Program (GHGRP), California’s Cap and Trade Program, Canada’s Greenhouse Gas Reporting Program (GHGRP) and the EU’s Emissions Trading System (EU ETS).3 Direct biogenic testing of flue gas emissions has been well established in these programs, for example quarterly testing and reporting has been successfully implemented by the U.S. GHGRP for more than 12 years.
Co-Firing and Waste to Energy
Another relevant application of biogenic content testing in these industries is the use of municipal solid waste (MSW) combustion to produce energy, both on its own and in combination with traditional feedstock combustion like coal. Given the heterogeneous nature of MSW, it can be difficult to quantify the amount of renewable content combusted in waste to energy and co-firing operations. By allowing producers to directly measure emissions from these operations, biogenic testing allows regulators to track and incentivize the renewable portion of these operations.
Regulatory programs focused on emissions reductions which require direct biogenic testing for waste to energy and co-firing facilities include the U.S. EPA’s Greenhouse Gas Reporting Program (GHGRP), California’s Cap and Trade Program, Canada’s Greenhouse Gas Reporting Program (GHGRP) and the EU’s Emissions Trading System (EU ETS).4
Waste Derived Fuels
Another important application of biogenic content testing in these industries is for waste derived biofuels. Given their circular economic nature fuels derived from MSW, used cooking oils (UCO), and other wastes and residues can receive extra incentives from relevant regulatory programs because of their low to negative lifecycle emissions. Biogenic content testing allows producers of these fuels to demonstrate the amount of renewable content in the final product in order to receive these incentives.
Regulatory programs focused on lowering the carbon intensity of fuels that require direct biogenic testing for waste derived fuels include the U.S. Renewable Fuel Standard (RFS), California’s Low Carbon Fuel Standard (LCFS), Canada’s Clean Fuel Regulations (CFR) and the EU’s Renewable Energy Directive (RED).5
Landfill Derived Biogas and RNG
One other relevant application of biogenic content testing in these industries is for biogas derived from landfills, which is used to produce renewable natural gas (RNG). Similar to waste derived fuels, biogas, and RNG derived from landfills can have very favorable lifecycle assessments compared to virgin biofuels and are therefore eligible to receive added incentives under relevant regulatory programs. Biogenic content testing allows producers of these fuels to demonstrate the amount of renewable content in the biogas extracted from the landfill and the final RNG product.
Regulatory programs focused on lowering the carbon intensity of fuels that require direct biogenic testing for biogas and RNG derived from landfills include the U.S. Renewable Fuel Standard (RFS) and the EU’s Renewable Energy Directive (RED).6
The Key to Success
Relying on a recognized scientific standard for biogenic testing has played a critical role in the growth of these industry applications by providing a sound foundation for administering entities to measure the decarbonization achieved by these projects. Given the importance of these regulatory programs and tax incentives to the economic viability of these projects, standardized biogenic testing is critical to the success of these projects, as well as the emissions reduction goals to which they are contributing.
Standardized biogenic testing will also be key to the success of new emissions reduction programs as more states and countries continue to introduce them. As the global push for decarbonization gains momentum, reliable verification will play an important role protecting the integrity of emissions reduction programs and promoting low carbon alternatives. | WA
Benjamin Kling is a Policy Research Associate for Beta Analytic where he studies the use of biogenic and biobased content measurements in regulations around the world. Benjamin graduated from the University of Miami with his BA in International Relations and Political Science in 2020, his MA in International Administration in 2021 and joined Beta in 2022. His main research interests stem from the intersection of technological innovation, policy development and social change. For more information, call (305) 662-7760, e-mail [email protected] or visit www.betalabservices.com.
Notes
1. 2021. “Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis.” ASTM International
2. 2013. “ISO 13833:2013 Stationary source emissions: Determination of the ratio of biomass (biogenic) and fossil-derived carbon dioxide.” ISO
3. 2016. “40 CFR Part 98 Subpart C– General Stationary Fuel Combustion Sourc- es.” National Archives Code of Federal Regulations
2020. “Canada’s Greenhouse Gas Quantification Requirements.” Environment and Climate Change Canada
2022. “Biomass issues in the EU ETS.” European Commission
4. 2016. “40 CFR Part 98 Subpart C– General Stationary Fuel Combustion Sourc- es.” National Archives Code of Federal Regulations
2020. “Canada’s Greenhouse Gas Quantification Requirements.” Environment and Climate Change Canada
2022. “Biomass issues in the EU ETS.” European Commission
5. 2010. “40 CFR Part 80 Subpart M– Renewable Fuel Standard.”
National Archives Code of Federal Regulations
2020. “Reporting Co-Processing and Renewable Gasoline Emissions Under MRR.” California Air Resources Board
2022. “Clean Fuel Regulations: Quantification Method for Co-Processing in Re- fineries.” Environment and Climate Change Canada
2023. “Renewable energy- method for calculating the share of renewables in the case of co-processing.” European Commission
6. 2023. “40 CFR Parts 80 and 1090– Renewable Fuel Standard (RFS) Program: Standards for 2023–2025 and Other Changes.” Environmental Protection Agency
2023. “Renewable energy- method for calculating the share of renewables in the case of co-processing.” European Commission
References
2010. “40 CFR Part 80 Subpart M– Renewable Fuel Standard.” National Archives Code of Federal Regulations https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-80/subpart-M
2013. “ISO 13833:2013 Stationary source emissions: Determination of the ratio of biomass (biogenic) and fossil-derived carbon dioxide.” International Organization for Standardization
2016. “40 CFR Part 98 Subpart C– General Stationary Fuel Combustion Sources.” National Archives Code of Federal Regulations https://www.ecfr.gov/
current/title-40/chapter-I/subchapter-C/part-98/subpart-C
2020. “Reporting Co-Processing and Renewable Gasoline Emissions Under MRR.” California Air Resources Board https://ww2.arb.ca.gov/sites/default/files/2020-09/MRR_coprocessing-slides_Sept_2020.pdf
2020. “Canada’s Greenhouse Gas Quantification Requirements.” Environment and Climate Change Canada https://publications.gc.ca/collections/collection_2021/eccc/En81-28-2020-eng.pdf
2021. “Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis.” ASTM International (D6866-21). pp 1-19. doi: 10.1520/D6866-21.
2022. “Biomass issues in the EU ETS.” European Commission
Click to access gd3_biomass_issues_en.pdf
2022. “Clean Fuel Regulations: Quantification Method for Co-Processing in Refineries.” Environment and Climate Change Canada
www.canada.ca/en/environment-climate-change/services/managing-pollution/energy-production/fuel-regulations/clean-fuel-regulations/compliance/
quantification-methodco-processing-refineries.html
2023. “Renewable energy- method for calculating the share of renewables in the case of co-processing.” European Commission https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12711-Renewable-energy-method-for-calculating-the-share-of-renewables-in-the-case-of-co-processing_en
2023. “40 CFR Parts 80 and 1090– Renewable Fuel Standard (RFS) Program: Standards for 2023–2025 and Other Changes.” Environmental Protection Agency www.epa.gov/renewable-fuel-standard-program/final-renewable-fuels-
standards-rule-2023-2024-and-2025