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Mandatory RNG Certificate Disclosure (Long)
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Switching to biomethane from fossil-derived gas is one available climate solution for organizations seeking to decarbonize methane combustion. In addition to reducing demand for conventional gas, biomethane consumption can have significant environmental benefits by incentivizing capture of otherwise released methane (See WRI’s Renewable Natural Gas as a Climate Strategy: Guidance for State Policymakers). In order to claim consumption of biomethane delivered via a common carrier pipeline, organizations must procure and retain RNG certificates (renewable thermal certificates, green gas certificates, or biogas certificates).
RNG certificates are a relatively new commodity compared to electricity-derived energy attribute certificates (EACs), and reporting requirements are still under development for some corporate sustainability initiatives. Notably, the Greenhouse Gas Protocol’s (GHGP’s) Corporate Reporting and Accounting Standard has not yet confirmed the applicability of RNG Certificates to reduce scope 1 emissions.
This memo outlines five key details related to market support for the procurement of RNG certificates, existing reporting requirements, and where guidance is still under development. This is a complicated issue and there won’t be final answers for several years. [COMPANY] is tracking closely in order to convey full information and perspectives clearly to our clients.
1- RNG certificates substantiate a claim to renewable energy fuel consumption delivered via a common carrier pipeline under both compliance and voluntary fuel and energy reporting regimes.
RNG certificates are used in a number of voluntary and compliance frameworks to substantiate a claim of consuming renewable energy fuel, and the associated emissions profile, from a common carrier pipeline. Each program has its own unique eligibility requirements for certificates. These include:
Several corporate renewable energy and GHG accounting frameworks (see #2 below)
Voluntary claims for European organizations under RED II
All North American Clean Fuel Standards (currently British Columbia, California, Canada, Oregon, Washington, and US Renewable Fuel Standard)
Carbon policy compliance in North America, such as California’s Cap-and-Trade
Utility mandates and goals to deliver biomethane to customers (e.g. California SB1440, Oregon SB98, and Washington HB1257)
RNG certificates are necessary because common carrier pipelines are generally the most efficient way to transport gas and liquid fuels, but tracking unique molecules of gas from the point of injection to the point of consumption is not possible. This means renewable fuels delivered through a shared pipeline are indistinguishable from fossil-based fuels.
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Mandatory RNG Certificate Disclosure (Long)
General Agreements