c,%
/A\
\ ^ *
° s.
Methane Challenge Program Continuous Improvement Update
Create a Commitment for Supply of Renewable Natural Gas
Proposed by: Methane Challenge Program
Date finalized: March 25, 2021
Category of change: Finalizing a new BMP commitment and adding additional data elements to
ONE Future reporting
Summary of change: Develop a commitment for reporting on supply of renewable natural gas
through natural gas transmission and distribution systems.
Overview
Through the Methane Challenge Program ("the Program"), EPA encourages Partners to make ambitious
commitments to reduce natural gas (methane) emissions through broad scale implementation of cost-
effective technologies and practices. EPA recognizes ongoing advances in technologies and approaches
for identifying, measuring, and mitigating methane emissions and will consider creating new
commitment options, as well as revising approaches to track, implement, and report on current
commitments through the Continuous Improvement Process.1
This program update creates a new Best Management Practice (BMP) commitment under which natural
gas transmission and distribution companies that receive and supply renewable natural gas (RNG)
through their systems would report on this RNG. The intent of this commitment is to recognize efforts
that Partner companies are making to diversify their portfolio and their role in facilitating recovery and
use of otherwise-emitted methane from landfills, wastewater treatment plants, livestock farms, etc. By
transmitting and distributing RNG in their pipelines and systems to end users, transmission and
distribution companies are playing a valuable role in providing market access for these methane
recovery projects. The mission of several of EPA's voluntary methane outreach programs, including
AgSTAR and the Landfill Methane Outreach Program in particular, is to advance recovery and use of
otherwise-wasted methane from these sources. Methane Challenge Partners that adopt this
commitment will be advancing information about the extent of RNG projects and these projects' overall
impact in terms of reducing methane emissions from the biological decomposition of organic materials
at municipal solid waste landfills, water resource recovery facilities (wastewater treatment plants),
livestock farms, food production facilities, and organic waste management operations.
1 Details available on the Program website at https://www.epa.gov/natural-gas-star-program/methane-challenge-
continuous-improvement
Page 1 of 9
-------
The commitment will be available to both BMP and ONE Future commitment option partners.2
Companies that operate and deliver and/or supply RNG in states with regulations requiring that a
portion of natural gas delivered/supplied be RNG can participate in this commitment and should contact
the Methane Challenge program managers to discuss further.
About Renewable Natural Gas
For the purposes of this document and the commitment, "biogas" is gas produced by the anaerobic
digestion of organic matter at one or more of the following sources: municipal solid waste (MSW)
landfills, anaerobic digestion (AD) at municipal water resource recovery facilities (WRRFs), AD at
livestock farms, and AD at stand-alone organic waste management operations. For the purposes of this
document and the commitment, "renewable natural gas"3 encompasses biogas that has been upgraded
for use in place of fossil natural gas. In the reporting form for this commitment, partners will also have
the opportunity to provide general information about their companies' strategies for supplying other
"low carbon" fuels.
As a substitute for natural gas, RNG has many end-uses, including in thermal applications, to generate
electricity, for vehicle fuel, or as a bio-product feedstock. For the purpose of this commitment, all of
these end-uses are appropriate, and the end-use would be a requested, but not required, data element.
RNG can be used locally at the site where the gas is produced and upgraded, or it can be injected into
natural gas transmission or distribution pipelines. This commitment is focused on natural gas injected
into transmission or distribution pipelines.
Raw biogas has a methane content between 45 and 65 percent, depending on the source of the
feedstock, and must go through a series of steps to be converted into RNG. Treatment includes
removing moisture, carbon dioxide (C02) and trace level contaminants (including siloxanes, volatile
organic compounds, or VOCs, and hydrogen sulfide), as well as reducing the nitrogen and oxygen
content. Once upgraded, the gas has a methane content of 90 percent or greater. Typically, RNG
injected into a natural gas pipeline has a methane content between 96 and 98 percent.
Additional information on renewable natural gas can be found in a discussion paper published by EPA's
voluntary methane programs in 2020: https://www.epa.gov/lmop/overview-renewable-natural-gas-
biogas
Methane Challenge RNG Commitment
This commitment will apply to RNG that is injected into natural gas transmission and distribution
systems. This commitment will not encompass RNG attributes that are purchased, unless the gas is also
2 BMP partners would make a new commitment to "Renewable Natural Gas" and would include RNG data on the
new RNG tab in their reporting forms. ONE Future partners would not make a separate commitment and would
include RNG data on the new RNG tab in their reporting forms. RNG data from both commitment options will be
published on the partner profile pages.
3 There are many different definitions of renewable natural gas currently used; these definitions are specifically
tailored to each context. For example, the American Gas Association has developed this consensus definition:
"Renewable natural gas (RNG) is any pipeline compatible gaseous fuel derived from biogenic or other renewable
sources that has lower lifecycle C02e emissions than geological natural gas". Further information on AGA's
definition can be found at this URL: https://www.aga.org/natural-gas/renewable/
Page 2 of 9
-------
directly injected into the Partner's system or another system that is physically connected to the
Partner's system.4 For the purpose of this commitment, the biogas used to produce RNG may be derived
from one or more of the following sources: municipal solid waste landfills, digesters at water resource
recovery facilities (wastewater treatment plants), livestock farms, food production facilities, and organic
waste management operations.
In making a Methane Challenge commitment to Renewable Natural Gas, a Partner in the transmission or
distribution segments will need to directly receive (i.e., via pipeline interconnect or virtual pipeline-
transportation via truck) or deliver or supply RNG generated by a biogas project (i.e., from a municipal
solid waste landfill or from a digester at a water resource recovery facility, livestock farm, food
production facility, or organic waste management operation).
Companies that operate and deliver/supply RNG in states with regulations requiring that a portion of
natural gas delivered/supplied be RNG can participate in this commitment and should contact the
Methane Challenge program managers to discuss further.
Within 5 years of its commitment start date, the Partner commits to:
• Annually report RNG data elements to the Program;
• Research the nature and extent of RNG in its system (i.e., information about the biogas project
that generated the gas and how the gas is being used by end users) so that the Partner can
report as complete a representation of the RNG it has acquired, transported, and delivered as
possible by the end of its commitment. However, EPA recognizes that transmission and
distribution companies may not be privy to all the information being requested, particularly
about the end use of the RNG in their systems.
The primary goal of this commitment is to share data on RNG supply through natural gas systems, to
develop a more robust understanding of the extent and nature of RNG distributed and used through
natural gas systems. As such, this commitment will focus on collecting and publishing data from Partners
that make an RNG commitment. Partners that make this commitment will have the RNG commitment
added to their Partner Profile Webpage and their RNG data added to their Methane Challenge Data
Download. The dataset would include information on the biogas project(s) that generate the RNG, the
pipeline interconnect(s) with the Partner company's system, and the designated end use of the RNG.
Recognizing that the Partner company may not have all the information requested, the Program does
not plan to create or track a 'commitment progress metric' for this commitment at this time. However,
the Program does encourage the Partner to work on understanding as much about the RNG in its system
as possible by the end of its commitment.
If the project(s) from which a Partner receives all its RNG permanently go(es) offline during its
commitment, the Partner should report this to the Methane Challenge Program as soon as possible. If
the Partner does not plan to source RNG from another project, it can change its 'Commitment
Achievement Year' to the year the project went offline and would not be required to report when not
sourcing RNG.
4 Methane Challenge certainly does not expect to "track molecules" of RNG, but there should be pipeline
connections that would theoretically allow the gas to travel to the partner's system.
Page 3 of 9
-------
Reporting Approach
Methane Challenge reporting is done at the facility level, through the electronic Greenhouse Gas
Reporting Tool (e-GGRT) system. The RNG data will be reported through the same mechanism. EPA's
intention is to set up the reporting form to allow Partners to report the requested data elements for
each RNG biogas project/end use in its system. Partners will be asked to report the information about
the biogas project(s) from which the RNG was sourced, the interconnect(s) through which the RNG was
injected into the Partner's system, and the designated end use(s) for the gas.
Methane Challenge is defining a robust set of data elements for this commitment because it is entirely
focused on reporting. By offering this detailed set of data elements, partners that have information and
want to share it will have an opportunity to do so. However, EPA recognizes that transmission and
distribution companies may not be privy to all information being requested, particularly about the end
use of the RNG in their systems and especially if the company is not both receiving the gas from an RNG
project and supplying it to customers. Further, if any data are considered confidential (e.g., by the
biogas project developer) and the partner cannot report them, the partner should not report these data
and can indicate that the requested data are confidential and cannot be shared in the applicable free-
text field.
As such, all data elements will be considered optional and are requested to be reported if feasible for
the partner company. It is not expected that all partners will report all data elements and companies
that cannot report all requested data will not be penalized in any way.
As an outcome of this commitment, EPA intends to gather and publish data on the volumes of RNG
injected into transmission and distribution systems to enhance understanding of the magnitude of
"biogas methane emissions avoided" by the supply of RNG to end users. Partners should only report on
RNG (1) that they receive directly from a biogas project (i.e., the RNG is directly injected into the
Partner's system at an interconnect) or (2) that they receive via interconnect with another natural gas
company and deliver and/or supply to their customers. Partners should not report on RNG attributes
that are purchased unless the gas is directly injected into the Partner's system or another system that is
physically connected to the Partner's system.
Specific data elements for Methane Challenge reporting on this commitment are detailed in Appendix A.
A Note about ElA's 176 Reporting Updates
At the time this version of the proposal was finalized, EIA had not yet finalized updates to its 176 Natural
Gas Supply annual reporting for 2021-2024. As described in its Federal Register notice on December 8,
2020s, EIA is proposing to make the following modification to the 176 data collection:
EIA is modifying the survey instructions to include Renewable Natural Gas (RNG) producers who
inject high-Btu RNG into an interstate pipeline, intrastate pipeline, or natural gas distribution
company system. This excludes on-site and local pipelines that deliver to a nearby end-user, such
as to a CNG fueling station or power plant EIA is adding this type of RNG producer because these
facilities produce the equivalent of pipeline-quality natural gas that is not captured elsewhere in
EIA's production statistics.
5 https://www.federalregister.gov/documents/2020/12/08/2020-26884/agency-information-collection-extension
Page 4 of 9
-------
Methane Challenge does not expect this change to affect natural gas transmission and distribution
companies that would report to Methane Challenge. Nevertheless, Methane Challenge will review the
final specifications for EIA 176 reporting when they are published. If any of the Methane Challenge data
elements are ultimately included in ElA's reporting requirements for natural gas transmission and
distribution companies, these data elements will not need to be reported to EPA. In this scenario,
Methane Challenge partners would be asked to provide EPA with the Company ID in the EIA dataset that
corresponds to each of their Methane Challenge facilities.
Page 5 of 9
-------
Appendix A. Updates to Methane Challenge BMP Technical Document
Renewable Natural Gas
Applicable Segments: Transmission & Storage; Distribution
Source Description: This commitment addresses the supply of renewable natural gas (RNG) through
natural gas transmission and distribution systems. For the purposes of this commitment, "biogas" is gas
produced by the anaerobic digestion of organic matter at one or more of the following sources:
municipal solid waste (MSW) landfills, anaerobic digestion (AD) at municipal water resource recovery
facilities (WRRFs), AD at livestock farms and AD at stand-alone organic waste management operations.
For the purposes of this commitment, "renewable natural gas"6 encompasses biogas that has been
upgraded for use in place of fossil natural gas. In the reporting form for this commitment, partners will
also have the opportunity to provide general information about their companies' strategies for
supplying other "low carbon" fuels.
Raw biogas typically has a methane content between 45 and 65 percent, depending on the source of the
feedstock, and must go through a series of steps to be converted into RNG. The treatments used will
depend on the source of the raw biogas and the constituents found in the raw biogas. These may
include removing moisture, carbon dioxide (C02) and trace level contaminants (which, depending on the
biogas source, can include siloxanes, volatile organic compounds- VOCs, and hydrogen sulfide), as well
as reducing the nitrogen and oxygen content. Once upgraded, the gas has a methane content of 90
percent or greater.
As a substitute for natural gas, RNG has many end-uses, including in thermal applications, to generate
electricity, for vehicle fuel, or as a bio-product feedstock. For the purpose of this commitment, the end-
use is a requested, but not required, data element. To develop a greater understanding of the RNG
market and the role of natural gas transmission and distribution systems in advancing use of RNG, the
end use is a valuable piece of information. However, EPA recognizes that transmission and distribution
companies may not be privy to the information about the end use of the RNG projects for RNG in their
systems.
RNG can be used locally at the site where the gas is produced and upgraded, or it can be injected into
natural gas transmission or distribution pipelines. This commitment is focused on natural gas injected
into transmission or distribution pipelines. This commitment does not encompass RNG attributes that
are purchased, unless the RNG is directly injected into the Partner's system or another system that is
physically connected to the Partner's system.
Additional information on renewable natural gas can be found in a discussion paper published by EPA's
voluntary methane programs in 2020: https://www.epa.gov/lmop/overview-renewable-natural-gas-
biogas
6 There are many different definitions of renewable natural gas currently used; these definitions are specifically
tailored to each context. For example, the American Gas Association has developed this consensus definition:
"Renewable natural gas (RNG) is any pipeline compatible gaseous fuel derived from biogenic or other renewable
sources that has lower lifecycle C02e emissions than geological natural gas". Further information on AGA's
definition can be found at this URL: https://www.aga.org/natural-gas/renewable/
Page 6 of 9
-------
Partners Commit To:
• Annually report RNG data elements to the Program;
• Research the nature and extent of RNG in its system (i.e., information about the biogas project that
generated the gas and how the gas is being used by end users) so that the Partner can report as
complete a representation of the RNG it has acquired, transported, and delivered as possible by the
end of its commitment.
Commitment Timeframe: Partners commit to report as many data elements as possible annually and to
research the nature and extent of RNG in their systems by the designated commitment achievement
date, not to exceed five (5) years from the commitment start date. If the project(s) from which a Partner
receives its RNG permanently go(es) offline during its commitment, the Partner should report this to the
Methane Challenge Program as soon as possible. If the Partner does not plan to source RNG from
another project, it can change its 'Commitment Achievement Year' to the year the project went offline
and would not be required to report when not sourcing RNG.
Facility-level Annual Reporting:
Data will be reported at the facility-level through e-GGRT as for other BMP commitments. The RNG
reporting form tab will be set up so Partners can report the requested data elements for each biogas
project (if more than one). Partners can also use multiple lines per category to indicate multiple
interconnects, designated end uses, etc. Data should only be reported on RNG that is received directly
from an interconnect with a biogas project or a virtual pipeline or that is received from another system
that is physically connected to the Partner's system and that is then delivered and/or supplied to
customers by the partner.
All data elements for this commitment option are OPTIONAL and to be provided if feasible. If data are
considered confidential (e.g., by the biogas project developer) and the partner cannot report them,
the partner should not report these data and can indicate that the requested data are confidential
and cannot be shared in the applicable free-text field. It is not expected that all partners will report all
data elements and companies that cannot report all requested data will not be penalized in any way.
Data Category
Data Elements Collected via Facility-Level Reporting
General
Information
What role(s) does your company play in the RNG process? (please indicate all that apply)
[Investing in biogas projects; Directly interconnecting with biogas project; Delivering RNG
to end users; Supplying RNG to end users; Purchasing environmental attributes for RNG
that is physically connected to the company's system; Purchasing environmental attributes
for RNG that is not physically connected to the company's system]
For Distribution Partners7-
• Does your company offer a 'green gas' option to residential customers?
• Is your company in the process of offering a 'green gas' option?
Any additional information on the role(s) your company plays in the RNG process, or about
'green gas' offerings?
7 If your company operates in multiple states and is in different phases of offering 'green gas' to customers in the
different states, you can provide additional details in the 'additional information' free text field.
Page 7 of 9
-------
Data Category
Data Elements Collected via Facility-Level Reporting
Information
about the
biogas source
Biogas Project ID8
What is the feedstock for the biogas? (Anaerobic digester - livestock farm; Anaerobic
digester - co-digestion; Anaerobic digester - food production facility; Anaerobic digester -
organic waste management; Anaerobic digester - wastewater treatment plan; Landfill;
Other (Specify)9)
Name the specific municipal solid waste landfill or digester (i.e., at water resource recovery
facilities (wastewater treatment plants), livestock farms, food production facilities or
organic waste management operations) from which the RNG was generated
What upgrading technology was used? [to be selected from a list]
Any additional information on the biogas project/upgrading process you wish to share?
Information
about the
pipeline
interconnect(s)
Type of interconnect [Direct interconnect with biogas project; Interconnect with natural
gas transmission company delivering/transporting RNG; Interconnect with natural gas
distribution company delivering/transporting RNG; Interconnect with natural gas
distribution company delivering and supplying RNG]
If interconnect with natural gas transmission company or distribution company, name of
interconnecting company
If interconnect with biogas project:
• Biogas Project ID10
• Location of the interconnect (latitude/longitude)
• Volume of gas received this year (scfgas)
• Reference to the company's gas quality standards that are applicable to this
project (e.g., pipeline tariff)
• How far is the interconnect from the feedstock source (km)?
• Is there a virtual pipeline?
o If yes, details about the virtual pipeline
Any additional information on the interconnect process you wish to share?
Information
about the end
use(s) and
environmental
attributes
Biogas Project ID [if known]11
What is the destinated market for the RNG (region/city/state/facility) [if known]?
What is the designated end use [if known]? (Thermal applications; Electricity generation;
Vehicle fuel; Bio-product feedstock; Interconnect with other natural gas company (specify
company); Not designated; Other (specify end use); Unknown)
Volume of RNG going to this end use, this year (scfgas) [if known]
Any additional information on the end use you wish to share?
8 This ID is to be generated by the reporting partner and can be of any alphanumeric format desired. The same ID
should be used for any given project across the different tables on the reporting form.
9 If project feedstock is a combined waste stream, please specify the waste streams using the nomenclature
from the drop-down list
10 This ID is to be generated by the reporting partner and can be of any alphanumeric format desired. The same ID
should be used for any given project across the different tables on the reporting form.
11 Ibid.
Page 8 of 9
-------
Data Category
Data Elements Collected via Facility-Level Reporting
Does your company currently own the environmental attributes for the RNG? [Yes; No;
Unknown]
If your company does not own the environmental attributes now, who does? [If known]
If, your company does, or at one point did, own the attributes for RNG, does your supply
contract for "renewable" natural gas include conveyance of environmental attributes
to your company (e.g., by way of a contract clause, attestation)? [Yes; No; Unknown]
If your company is selling "renewable" natural gas supply to another downstream
entity (e.g., distributor, end consumer etc.), have you contractually conveyed the RNG
environmental attributes to the downstream buyer? [Yes; No; Unknown]
Is your company using a third party provider to certify or track attributes? If so, which
one(s)?
Any additional information about environmental attributes that you wish to share?
Information
about the
Company's
strategy for
supply of "low
carbon fuels"
Company-specific goals or strategies for supply of "low carbon fuels" (such as upgraded
biogas, hydrogen, etc.) (e.g., percent of natural gas supply to be RNG by a certain year;
convert vehicle fleet to run on natural gas and use RNG for fuel), if applicable.
Is your company blending hydrogen into its natural gas supply? [Yes; Planning to;
Researching; No; Unknown]
If yes, or planning to/researching:
• At what rate will you be blending (% hydrogen by volume)
• What is the source and/or feedstock of the hydrogen? (e.g.,
renewable/nuclear/etc.)
• Is any upgrading/cleaning of the hydrogen required before injection?
• What pipeline types does your company inject hydrogen into (material and
pressure)?
• Have you done any related customer engagement?
• Has anything been done to customer appliances (if yes, what)?
Page 9 of 9
------- |