3Degrees’ Regulatory Affairs Manager, Noah Bucon explores the details of the European Commission’s plan, REPowerEU, and how this plan builds off of the European Green Deal and Fit for 55 package.
Review our key takeaways from the plan below.
A successful clean energy transition must include near-term decarbonization of the gas sector, which will be underpinned by a number of complementary solutions. In addition to expanding electrification, investing in energy efficiency, and addressing pipeline leakage, we also need to shift necessary near-term natural gas usage toward renewable resources. Also known as renewable natural gas (RNG), biomethane is chemically equivalent to fossil natural gas and can provide a range of economic and environmental benefits in the energy sector. This article highlights the benefits of RNG and describes how a new Green-e certification program helps ensure the integrity and impact of RNG procurement.
According to the U.S. EPA, almost 30 percent of human-caused methane emissions in the United States come from organic wastes that are managed at farms, landfills, and water resource recovery facilities. Emissions from these sources of waste can be captured and upgraded to RNG, which can then be used to displace fossil natural gas in common carrier pipelines. In addition to the resulting greenhouse gas emission benefits, this process also helps address local air and water pollution by creating incentives for improved waste management processes. Additionally, fuel-switching to RNG supports opportunities for local economic growth and supports energy independence.
RNG plays a unique role in deep decarbonization initiatives by providing a proven solution for difficult-to-electrify sectors, and it is becoming increasingly intertwined with state regulations and incentives focused on designing pathways to carbon neutrality. Utilities are also under increasing pressure from customers to offer solutions that allow customers to address emissions caused by their use of natural gas. The past few years have brought an influx of natural gas utilities developing, filing, and implementing voluntary programs that meet this demand. There are also growing opportunities for corporates to purchase RNG certificates for book-and-claim accounting. However, until recently, these transactions lacked standardization for credible claims, supply quality, and impact.
The Green-e Renewable Fuels Program fills this gap in the market and seeks to accelerate the adoption of biomethane across the United States and Canada. It was developed by the non-profit Center for Resource Solutions (CRS) in consultation with other environmental NGOs and market participants, including 3Degrees. CRS has a long track record in this space, having operated the Green-e Energy certification program for over 20 years, and in 2020, the organization certified over 90 million MWh of retail renewable energy sales.
The fundamental goal of the Renewable Fuels Program is to ensure that RNG supply is sourced from sustainable and renewable resources that meet the highest environmental standards, and that customers are protected in their purchase and their ability to make verifiable usage claims. The primary document governing this program is the Renewable Fuels Standard. The Standard sets a common unit for RNG transactions – the Renewable Fuel Certificate – and contains requirements regarding the environmental and transactional criteria that RNG supply must meet in order to be eligible for certification. The following fuel pathways are permitted, subject to specific environmental impact criteria for each feedstock: wastewater, municipal solid waste, vegetative matter, crop residue, and animal waste. Anaerobic digestate must also be sustainably managed, for example, by utilizing the American Biogas Council’s Digestate Certification Program.
Furthermore, upstream emissions from eligible fuels must be at least 10% lower than the carbon intensity of fossil natural gas up to the point of injection. Carbon intensity calculations must be made using CRS-approved methodologies and verified by a third party. There are also vintage matching criteria to ensure credible usage claims. With some minor exceptions, until 2026, RNG injected into the common-carrier pipeline during the reporting year or the four preceding calendar years will be eligible for certification. Beginning in 2026, the vintage window will narrow to the reporting year and the previous calendar year, intending to drive new project development over time.
The second governing document for this program is the Renewable Fuels Code of Conduct, which details requirements for product marketing, consumer disclosures related to supply characteristics, and disclosures related to price, terms, and conditions. The intention of the Code of Conduct is to ensure that end-use consumers understand what they are paying for, and that when they do receive a certified product, they can verify what they have purchased and claimed. All requirements related to the Green-e Renewable Fuel Standard and Code of Conduct are audited by third parties and then approved by CRS on an annual basis.
RNG supply is increasing around the world and presents an opportunity for us to address local environmental concerns, mitigate climate change, support local business owners, and establish independence from fossil fuels. Currently, the Green-e Renewable Fuel Standard only covers transactions in the U.S. and Canada, but similar biomethane products are available in several European countries (see this article for more information). If you are a utility or a corporate customer interested in leveraging RNG as a near-term solution to address your natural gas emissions, feel free to reach out for further information on options that are available to mitigate your environmental impact.
Across the world, the private sector is increasingly doing its part to support the energy transition. In fact, as of Q2 2021, approximately 300 global companies are now members of the RE10o initiative, which means they have committed to using 100% renewable electricity across their global operations. To join, companies must meet RE100’s eligibility criteria and must commit to reaching a 100% target by 2050, though many companies have committed to reaching their target earlier. RE100 supports renewable electricity development by giving companies a public platform to make ambitious commitments, by setting technical criteria to ensure these targets are met with integrity, and by giving companies access to a community of peers to aggregate demand and share best practices.
When companies sign on to an RE100 commitment, they must ensure they are up to date with the initiative’s reporting guidance, which is reviewed and updated on an annual basis. To that end, there were some notable recent changes to RE100’s technical criteria. The most significant updates are listed below and apply to the 2021 reporting year:
RE100 requires that, outside of the regional markets that exist in the United States and Canada, as well as in Europe, all renewable energy must be sourced from the same country in which a company is claiming the consumption of that renewable energy. In other words, in most parts of the world, a country’s market boundary is its own geographic borders. In defining what constitutes a market boundary, RE100 aligns with the Greenhouse Gas Protocol’s guidance for market-based instruments and considers: 1) physical grid connection and coordination, 2) regulatory consistency across electricity sectors, and 3) mutual recognition of renewable energy instruments between countries. Adhering to market boundaries is a critical component of a credible renewable energy claim.
The greatest challenges to meeting a global RE100 target are often associated with geographic restrictions around procurement. There are many countries around the world — primarily in Latin America, Africa, and Asia — that have limited or virtually no market-based options for purchasing renewable energy. Although financially attractive and impactful, on-site generation is not always a realistic option due to either limited space, local regulations, or complications associated with facility ownership.
Companies faced with geographic eligibility challenges may do the following:
Understanding how to reach a global 100% renewable electricity target that balances impact, cost effectiveness, and compliance with reporting requirements can be complicated and is especially challenging for companies with operations across multiple continents. Companies committing to RE100 must first ensure they understand the current reporting criteria and should identify the greatest barriers to reaching their target. Additionally, companies that want to follow RE100 recommendations should consider adding ecolabels, such as the Green-e®, EKOenergy, and Peace REC programs, to their renewable energy purchases to improve the integrity and impact of their procurement.
If your company is seeking to understand and address barriers to achieving an RE100 target, or is interested in maximizing the environmental and social impact of your renewable energy purchases, please feel free to reach out to us. We’re happy to help.
Since the World Resources Institute (WRI) unveiled new guidance for Scope 2 emissions accounting within the Greenhouse Gas Protocol Corporate Standard back in 2015, there has been an increased focus on global energy purchasing, with more organizations looking for options across the globe.
One such option is the Guarantee of Origin (GO), a voluntary renewable energy product that is used to claim consumption of renewable energy in Europe. A GO represents one megawatt hour of electricity from a renewable resource. Similar to a REC in the U.S., a GO represents the environmental attributes (but not the power) associated with renewable energy. Although all European countries are required to use GOs to track renewable energy consumption, not all have joined the Association of Issuing Bodies (AIB), which ensures adherence to best practices and market rules.
In countries that have joined the AIB, the European Energy Certificate System (EECS) certifies and registers each GO, preventing double counting and identifying the source of the GO and the method of production. In some countries, GOs may also be used to track renewable natural gas as well as some nonrenewable resources, so it is important to specify the type of GO desired when procuring these instruments. GO certificates are viable for 12 months from the date of issue.
The European voluntary market is well defined with clear norms of transparency and accountability. However, there are some complexities to the market that are important to understand. Although the EECS system creates rules around the creation and transfer of GOs, there are some country specific rules that can impact customers, specifically around project eligibility and GO cancellation. Although Europe is considered to be a single market, GOs are intended (where possible) to be cancelled in the GO registry of the country in which renewable energy claims are made. Due to a patchwork of trading/cancellation restrictions across the continent, this requirement can add administrative complexity for companies with operations in multiple countries. 3Degrees works closely with our clients to help them navigate the logistics of making EU-wide renewable energy claims in line with market rules.
Note: As of Q1 2020, Latvia, Montenegro, and Portugal are in the process of applying to join the Association of Issuing Bodies (AIB).
Interested in learning more about global renewable energy options? Read our blog on Navigating the Opportunities and Pitfalls of International Renewable Energy Markets or this case study on how Verisk is successfully addressing emissions from its global energy load.
In 2015, the World Resources Institute (WRI) unveiled new guidance for Scope 2 emissions accounting within the Greenhouse Gas Protocol Corporate Standard. This update introduced a market-based accounting mechanism that gives companies the opportunity to reduce their Scope 2 emissions through the purchase of renewable energy certificates, PPAs, and other contractual instruments. This provision has driven a new focus on global energy purchasing, with more organizations looking for options across the globe.
The I-REC, an international renewable energy certificate, represents transferrable proof that one MWh of electricity was produced from renewable energy sources and added to an electrical grid. Purchasing an I-REC allows the buyer to claim consumption of one MWh of renewable energy. I-RECs can originate from wind, solar, ocean energy, biomass, hydropower, landfill gas, aerothermal, geothermal, and landfill gas projects. 3Degrees only transacts I-RECs issued in countries authorized by the International REC Standard and traded on the I-REC Registry. This standard establishes rules and regulations for a transparent system that simplifies claims and eliminates double counting issues, making products compliant with Scope 2 reporting guidelines. Valid renewable energy claims also depend on additional factors, such as whether production and consumption occur within an appropriate market boundary.
In some cases, the I-REC Secretariat implements country-specific restrictions on certificate issuance to ensure environmental integrity and prevent double counting. For example, issuance would be prohibited for generation that is counted toward a state-mandated renewable energy delivery quota. Every country’s regulatory environment is unique, and even though a policy may not lead to double counting, it may nonetheless change the scope of claims an I-REC purchaser can make. 3Degrees’ Regulatory Affairs team reviews each country in which I-REC issuance is authorized to comprehensively understand and communicate the integrity and impact of our clients’ I-REC purchases.
Interested in learning more about global renewable energy options? Read our blog on Navigating the Opportunities and Pitfalls of International Renewable Energy Markets or this case study on how Verisk is successfully addressing emissions from its global energy load.
Europe is by far the largest and most liquid market for energy attribute certificates globally, and it is poised for further expansion. For decades, Guarantees of Origin (GOs) have been used to claim the consumption of renewable electricity in Europe. Now, the GO system, which is enshrined in EU law through the Renewable Energy Directive, is being expanded to cover other energy carriers, specifically biomethane (also known as renewable natural gas) and hydrogen. In the coming months and years, companies will see increasingly accessible opportunities to use gas GOs to address their Scope 1 emissions on their journey to net zero. Compared to electricity markets, though, markets for renewable gases in Europe are nascent and exceedingly heterogeneous.
The recast Renewable Energy Directive (RED II) requires the use of GOs to claim consumption of renewable energy. While this has become commonplace for renewable electricity claims in Europe, it is still an emerging option for renewable gases and is likely to be less familiar to many companies. This lack of familiarity can be compounded by the fact that the European gas GO market is fragmented, technically complex, and evolving quickly. Because of RED II requirements, EU member states are mandated to be actively implementing gas GO systems — or updating their existing GO systems — to accommodate energy carriers other than electricity.
Despite momentum at the EU level, there are currently only a handful of countries in Europe that have registries that can accommodate the issuance and trade of gas GOs, including Germany, Austria, France, Denmark, Lithuania, the Netherlands, and the United Kingdom. Although it did exit from the EU, the UK is actually one of the most mature markets for gas GOs in Europe. These countries with active gas GO registries are members of the European Renewable Gas Registry (ERGaR), which is a membership organization dedicated to enabling the cross-border transfer of renewable gas certificates. While the market for gas certificates is moving toward increased cross-border fungibility, such functionality is still fairly limited. ERGaR has designed two gas certification systems: one that strictly utilizes book-and-claim accounting, and one that incorporates mass balancing calculations. It is possible that the mass balancing scheme could be used to comply with RED II transportation decarbonization mandates.
Another layer of complexity arises from the fact that the Association of Issuing Bodies (AIB), a membership organization that includes competent bodies responsible for the issuance of electricity GOs in 28 European countries, is expanding the European Energy Certificate System (EECS) to accommodate the issuance, trade, and cancellation of gas GOs. EECS Rules have been updated to incorporate energy carriers other than electricity, and so far seven AIB members have been appointed as the competent bodies for gas GO issuance. Although the AIB Hub will eventually streamline fungibility between countries, cross-border trading in the near term will be limited to countries with bilateral trade agreements.
The gas GO market will evolve significantly over the next year (or years, depending on the ambition of regulators). Companies seeking to use gas GOs to address Scope 1 emissions in Europe should be aware of three main areas of change.
Although the structures and rules of gas GO markets are evolving, this should not dissuade companies from becoming early participants in these markets. Sending early demand signals is crucial to kick-starting these markets, which will play a pivotal role in the EU bloc reaching its net zero by 2050 target. While EU-wide market rules are being finalized, and as stakeholders await updated Greenhouse Gas Protocol guidance, they should keep the following best practices in mind:
Markets for renewable gases are beginning to emerge in other regions of the world as well, most notably in the United States and Canada. If your company is seeking to understand how to best leverage emerging markets for renewable gas certificates to address your Scope 1 emissions, feel free to reach out to us. We are happy to help.
“Green growth” — the concept of decoupling economic expansion from negative environmental impacts — is by no means a new idea, but it is more frequently discussed in textbooks than in national legislation. In Europe, however, this is no longer the case. The European Green Deal is a commitment from the European Commission for the EU bloc to be climate neutral by 2050. The climate-related investments necessary to achieve this target are intended to serve as both a near-term stimulus to help the European economy recover from its pandemic-induced recession and a catalyst for a continent-wide green economy transition. While this cements the EU’s role as a global climate leader, European regulators are still in the very early days of making this commitment a reality. For companies seeking to proactively reduce their carbon footprint in Europe, the Green Deal is welcome news, and they want to learn more. Below are answers to some of the most common questions being asked.
The Green Deal is an aspirational commitment that will be underpinned by forthcoming EU-level legislation and then implemented via EU Member State policies and regulation. EU legislation will come in the form of the European Climate Law, which will bind Member States to the 2050 climate neutrality target, then national-level policy will follow suit. The European Commission has also committed to developing a Just Transition Mechanism to support the green economy transition in Member States that will be subject to the greatest economic hardship, i.e. those whose economies are most dependent on fossil fuels. The EU is committed to leaving no country behind in its pursuit of climate neutrality.
In addition to supporting biodiversity and agricultural initiatives, the Green Deal will also support clean energy and decarbonization across four key sectors:
While the Green Deal aims to reduce greenhouse gas (GHG) emissions by 55% by 2030 en route to zero by 2050, the EU’s 2030 renewable energy target remains at just 32%. For this reason, the European Commission is evaluating whether and how its Renewable Energy Directive should be adjusted and strengthened in the context of achieving the more ambitious targets set out by the Green Deal. Corporate renewable energy buyers can expect increasing accessibility to renewable power purchase agreements (PPAs), increasing reliance on Guarantees of Origin (GOs) to track electricity use, and increasing adoption of biomethane and hydrogen GOs in the gas sector. Companies with vehicle fleets can also expect enhanced fiscal support for the decarbonization of these services.
Green Deal investments will be jump-started by the Recovery Plan for Europe, which bolstered the COVID-19 recovery budget to €1.8 trillion, while committing 30% of these funds to fighting climate change. The European Commission expects it to cost approximately €1 trillion to reach its 2030 targets, with these funds coming from the EU budget, national governments, and the private sector. As the Green Deal commitments are gradually embedded into legislation and regulation across Europe, companies can expect an explosion of green growth opportunities, especially in the energy and transport sectors. They should also be aware of changing policy environments geared toward facilitating this green economy transition and should stay apprised of incentives for companies doing their part to become climate neutral by 2050.
Despite how ambitious and unprecedented the Green Deal is, the true test will come in the form of maintaining unity across the bloc and ensuring that investments are properly leveraged to efficiently support economic growth that benefits both people and the planet. Once successful, this initiative will serve as a proven blueprint for green economic recovery around the world.
If you have additional questions about the Green Deal, or how it might impact your organization’s emissions reduction plans in Europe, please feel free to reach out to us.
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