Setting the standards in the biofuel sphere

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As biofuels gain market traction their use has been increasingly motivated by new regulatory programmes and tax incentives. These programmes and incentives have quickly grown to be prominent, well-funded and increasingly widespread in both the US and the European Union.
A critical tool for the growth of these programmes has been the ability to measure the renewable portion of biofuels using biogenic testing vía the ASTM D6866 standard in order to incentivise the portion of the fuels contributing directly to decarbonisation.

What is biogenic testing?

Biogenic content testing uses carbon-14 analysis since the carbon-14 isotope is present in all living organisms, whereas petrochemical-derived material no longer contains any carbon-14 content.
Results are reported as a percentage, which reflects the portion of the biofuel produced from renewable feedstocks.
The most widely used international standard for biogenic content testing is ASTM D6866. Other similar standards such as EN ISO 16640 are more commonly used in programmes in Europe.
The use of widely recognised 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 fuel standards?

There are two major categories into which regulations designed to support the biofuels industry relevant to this discussion may be divided, namely fuel standards and tax incentives.
Tax incentives are credits or exemptions offered to biofuel producers, distributors or both. The more innovative and complicated of these policy instruments are fuel standards, which often have elements tied to tax incentives.
As a result, this article will focus on describing how fuel standards function and have developed, with specific emphasis on the role of biogenic testing in these programmes.
Fuel standards are programmes designed to decrease the carbon intensity (CI) of the fuel supply of the enacting governing body’s jurisdiction.
Fuel standards function by setting annual renewable volume mandates which are progressively raised.
Regulated entities receive credits corresponding to their use of renewables in that year and must submit a certain amount of credits to be in compliance with the programme.
Entities with a surplus of credits can sell them to those with too few or save them for future years.
The main division among fuel standards is between those that offer tax incentives tied to their credits, as opposed to those which mandate regulated entities to submit credits with no additional incentivisation.

Where are fuel standards in use?

US Renewable Fuel Standard
The United States’ Renewable Fuel Standard (RFS) is the country’s national fuel standard programme. This started with the Energy Policy Act (EPAct) of 2005 and was significantly expanded by the Energy Independence and Security Act (EISA) of 2007.
EISA established the annual renewable volume mandates for the first 15 years of the programme. 2023 will be the first year for which the EPA sets the volume mandates, as the White House is currently reviewing their proposed volumes for 2023, 2024 and 2025. The credits which drive the RFS are called renewable identification numbers (RINs) and they are tied to tax incentives offered through the programme. There were just under 21.27 billion RINs generated in 2022, up from about 19.93 billion in 2021.
The RFS requires biogenic content testing following the ASTM D6866 standard for any fuels produced from the co-processing of renewable and non-renewable feedstocks or from municipal solid waste (MSW).
For fuels produced from MSW, verifying biogenic content through testing further qualifies fuels for a specific type of RINs with a D-code of three, the most stringent category. For co-processed fuels the test results submitted are directly used to quantify the amount of gallon-RINs generated for that batch.

California’s Low Carbon Fuel Standard
The first US state to adopt its own fuel standard was California with the introduction of its Low Carbon Fuel Standard (LCFS) in 2011. The programme was amended into its current form in 2016. The LCFS is administered by California’s Air Resources Board (CARB). Its original goal was a 10% reduction in CI by 2020 and has progressed to a 20% reduction by 2030. As of last year, the programme has outpaced its set goals for CI reduction, reporting a 12.63% CI reduction compared to the established goal of 10%. The programme calculates CI scores using the CA-GREET model, which is on version 3.0.
California’s LCFS requires biogenic content testing following the ASTM D6866 standard for any fuels produced from co-processing and recommends its use for those produced from MSW. For combustion and process emissions from co-processed fuels the programme allows direct sampling of stack gasses following the ASTM D6866 standard.

Oregon’s Clean Fuels Program
Oregon became the second US state to enact a fuel standard programme with its Clean Fuels Program established in 2016. Oregon’s programme establishes three separate individual standards for gasoline and gasoline substitutes, diesel and diesel substitutes and alternative jet fuel under its umbrella. It calculates CI scores using the OR-GREET model, which is on version 3.0. The goal is to achieve a 10% reduction in CI by 2025, a 20% reduction by 2030 and a 37% reduction by 2035.
Oregon’s Clean Fuels Program requires biogenic content testing following the ASTM D6866 standard for any fuels produced from either co-processing or MSW. The program requires testing to be conducted at least once every quarter that either MSW or a co-processed or otherwise heterogeneous biogenic and fossil fuel is combusted in the unit.

New and Proposed Clean Fuel Standards
Washington became the third and most recent state to enact a fuel standard in 2021 with its Clean Fuel Standard. The programme’s goal is to achieve a 20% reduction in CI by 2034. Many states beyond the west coast are now considering implementing fuel standards, with relevant legislation introduced across the US since Washington began its program. Currently New Mexico, Minnesota, Michigan, Illinois, Vermont and New York have bills proposing some level of fuel standard, with many other states reportedly drafting similar bills. A bill proposing a federal fuel standard specific to sustainable aviation fuels (SAF) was recently introduced in the House as well.

Fuel standards internationally
Fuel standards are experiencing similar growth internationally. In Canada the Clean Fuel Regulations implements a fuel standard at the federal level, while British Columbia created its own LCFS at the province level. In the European Union the Renewable Energy Directive (RED II) was established in 2009 and has continued to evolve similar to the US RFS, with negotiations on a third RED currently underway. While the Canadian regulations cite ASTM D6866, the EU sets requirements in terms of European equivalent biogenic testing standards such as EN 16640.
Similar programmes have been proposed or started in many other countries around the world, with Brazil’s RenovaBio programme, South Korea’s RFS and Japan’s METI biofuels standards representing several of the most developed examples currently.

Relying on a recognised scientific standard for biogenic testing has played a critical role in the growth of these programs by providing a sound foundation for administering entities to measure the decarbonisation they have achieved. Standardised biogenic testing will also be key to the success of new programmes created in states with current proposals or which introduce them moving forward. As the biofuels market continues to grow rapidly to play a critical role in the decarbonisation process, reliable verification will play an even greater role in protecting the integrity of fuel standard programmes.

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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

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2023. “Brownley, Schneider Introduce Legislation to Reduce Carbon Emissions in Aviation.” Julia Brownley California’s 26th District juliabrownley.house.gov/brownley-schneider-introduce-legislation-to-reduce-carbon-emissions-in-aviation/

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2023. “Renewable & Low Carbon Requirements Regulation.” Government of British Columbia gov.bc.ca/gov/content/industry/electricity-alternative-energy/transportation-energies/renewable-low-carbon-fuels#

2023. “Renewable Energy Directive.” European Commission energy.ec.europa.eu/topics/renewable-energy/renewable-energy-directive-targets-and-rules/renewable-energy-directive_en

2023. “EPA Delivers Final RFS ‘Set’ Rule to White House OMB.” Biodiesel Magazine biodieselmagazine.com/articles/2518694/epa-delivers-final-rfs-undefinedsetundefined-rule-to-white-house-omb

For more information: This article was written by Benjamin Kling, policy research associate, Beta Analytic. Visit: betalabservices.com

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