Biomethane from Animal Waste: Updates to the Green-e® Renewable Fuels Standard

Join Center for Resource Solutions (CRS) and Southern Environmental Law Center (SELC) for an in-depth webinar introducing the newly updated Green-e® Renewable Fuels Standard, which now includes restrictive requirements for concentrated animal feeding operations (CAFOs) as eligible sources of biomethane production. This update reflected more than five years of collaborative research and stakeholder engagement with input from environmental organizations, industry experts, and community representatives.

During this session, we walked through the new requirements outlined in Appendix A of the standard and explain how these requirements ensure that any biomethane produced from CAFOs meets the highest environmental and sustainability benchmarks. Viewers gain insight into how the updated Standard protects communities and wildlife and enhances transparency in renewable fuel certification through the use of existing resources.

Transcript

1. Biomethane from Animal Waste Updates to the Green-e® Renewable Fuels Standard Rupali Tripathi MA NAGER, R ENEWA BL E FUELS CE NTE R FOR RESO URCE SO LUT IO NS Blakely Hildebrand SENIO R A TTORN EY SO UTHER N ENV IR ONME NTA L L AW CE NTE R NOVEMBER 10, 2025
2. Center for Resource Solutions Green-e ® Renewable Fuels Standard for Biomethane from Animal Waste Blakely Hildebrand November 10, 2025
3. Photo credit: Civil Eats
4. Credit: WUNC
5. Blakely Hildebrand, Senior Attorney bhildebrand@selc.org
6. Biomethane from Animal Waste Updates to the Green-e® Renewable Fuels Standard Rupali Tripathi MA NAG ER, R ENEWA BL E FUELS CE NTE R FOR RESO URCE SO LUTIO NS NOVEMBER 10, 2025
7. PAGE 7 Non-governmental Organization (NGO) creating policy and market solutions to advance sustainable energy since 1997. • Renewable energy and climate policy • Clean Energy Accounting Project (CEAP) • Advisory Services • Renewable Energy Markets annual conferences • Green-e® certification for suppliers and users of renewable electricity, carbon offsets, and renewable fuels in the voluntary market Center for Resource Solutions © 2025 Center for Resource Solutions. All rights reserved.
8. Why Certification? PAGE 8 © 2025 Center for Resource Solutions. All rights reserved.
9. PAGE 9 • Global leader in renewable electricity certification • Consumer protection for voluntary renewable electricity purchases • Over 140 million MWh in retail transactions certified in 2024, enough to power 4 out of 5 U.S. households for a month. Green-e® Certification © 2025 Center for Resource Solutions. All rights reserved.
10. Tracking Systems: • Issue tradable certificates • Based on meter data • No double issuance for the same dth • Review a producer’s existence, licensing, capacity, etc. Certificates and Certification: RFC Issuance vs Impact PAGE 10 Third-Party Certification: • Supplemental to a tracking system • Assess renewable fuel eligibility based on quality criteria such as environmental performance • Carbon intensity limits • No double selling or double claiming • Beyond state and federal requirements • Required customer disclosures and marketing oversight © 2025 Center for Resource Solutions. All rights reserved.
11. Consumer Credibility. Green-e® is the leading 3rd party verification in renewable energy markets. It is recognized by many businesses as the gold standard for renewable energy sourcing and is mentioned in many corporate sourcing policies and recognition programs. Risk Reduction. Protects against double counting and claiming, creating confidence in clean energy purchases. Quality Assurance. Certified renewable energy products meet rigorous environmental, sustainability, and marketing claims standards. Stakeholder-driven standards. Approved by an independent Governance Board, including important environmental stakeholders such as the Union of Concerned Scientists, Natural Resources Defense Council (NRDC), and CDP. Benefits of Certification PAGE 11 © 2025 Center for Resource Solutions. All rights reserved.
12. Green-e® Renewable Fuels Program PAGE 12 © 2025 Center for Resource Solutions. All rights reserved.
13. Participants PAGE 13 Objectives • Accelerate the adoption of and drive voluntary market demand for renewable fuels, while ensuring that the fuel is from sustainable renewable resources and meets the highest environmental standards • Ensure customers are protected in their purchase and ability to make verifiable usage claims Green-e® Renewable Fuels • Renewable fuel producers • Brokers • Marketers • Traders • Utilities • Retailers • End-consumers (buyers) Participant Types Retail and wholesale transactions for: • Bundled (fuel + RFCs) • Delivered via pipeline system • Trucked • Raw fuel delivered directly to consumer • Unbundled • Renewable fuel certificates (RFCs) Product Types © 2025 Center for Resource Solutions. All rights reserved.
14. Requirements & Verification PAGE 14 © 2025 Center for Resource Solutions. All rights reserved.
15. • Initial focus on biomethane from waste sources • Renewable hydrogen criteria coming in 2026 • Covers U.S. and Canada • Regulatory surplus required: no RINs or LCFS credits for the same dekatherm sold in a Green-e® certified transaction • Verification and audit required • No double counting, double selling, double claiming Code of Conduct • Consumer disclosures • Marketing compliance review Standard PAGE 15 © 2025 Center for Resource Solutions. All rights reserved.
16. PAGE 16 Requirements © 2025 Center for Resource Solutions. All rights reserved. •No production facility age requirement •No geographic restrictions for US and Canada if fuel is injected into common carrier pipeline •Based on year of certified transactions •2-year period •For 2026 certified sales, production range is: 1/1/2025 through 12/31/2026 • Upstream Carbon Intensity 10% lower than fossil natural gas • Disclosures required for upstream and midstream emissions • Methodology - CA-GREET (US) and GHGenius (Canada) • Fuel Type - RNG • Sources of production • Feedstocks for Anaerobic Digestion – wastewater, organic component of municipal solid waste, food waste, crop residue, and animal waste Production Pathways Carbon Intensity Facility Age and Location Fuel Production Vintage
17. PAGE 17 Requirements © 2025 Center for Resource Solutions. All rights reserved. •No production facility age requirement •No geographic restrictions for US and Canada if fuel is injected into common carrier pipeline •Based on year of certified transactions •2-year period •For 2026 certified sales, production range is: 1/1/2025 through 12/31/2026 • Upstream Carbon Intensity 10% lower than fossil natural gas • Disclosures required for upstream and midstream emissions • Methodology - CA-GREET (US) and GHGenius (Canada) • Fuel Type - RNG • Sources of production • Feedstocks for Anaerobic Digestion – wastewater, organic component of municipal solid waste, food waste, crop residue, and animal waste Production Pathways Carbon Intensity Facility Age and Location Fuel Production Vintage You • CAFOs were initially not an eligible resource in the Green-eⓇ Renewable Fuels Standard • CRS recently developed a set of stringent criteria that the CAFO producing animal waste would need to meet
18. CAFO Definition PAGE 18 © 2025 Center for Resource Solutions. All rights reserved. CAFOs – Concentrated Animal Feeding Operations Concentrated Animal Feeding Operation (CAFO): a. Large CAFO: Any farm over this size is considered a CAFO b. Medium CAFO: Considered a CAFO based on farm size AND if either of the following criteria is met; i. has a manmade ditch or pipe that carries manure or wastewater to surface water; or ii. the animals come into contact with surface water that passes through the area where they’re confined. c. Small CAFO: A farm at or below this threshold is only considered a CAFO if it has been designated a CAFO by a relevant permitting authority Animal Sector Size Thresholds (Number of Animals) Large CAFO Medium CAFO Small CAFO Cattle or cow/calf pairs 1,000 or more 300 - 999 less than 300 Mature dairy cattle 700 or more 200 - 699 less than 200 Veal calves 1,000 or more 300 - 999 less than 300 Swine (weighing over 55 pounds) 2,500 or more 750 - 2,499 less than 750 Swine (weighing less than 55 pounds) 10,000 or more 3,000 - 9,999 less than 3,000
19. CAFO Definition PAGE 19 © 2025 Center for Resource Solutions. All rights reserved. CAFOs – Concentrated Animal Feeding Operations Animal Sector Size Thresholds (Number of Animals) Large CAFO Medium CAFO Small CAFO Horses 500 or more 150 - 499 less than 150 Sheep or lambs 10,000 or more 3,000 - 9,999 less than 3,000 Turkeys 55,000 or more 16,500 - 54,999 less than 16,500 Laying hens or broilers (liquid manure handling systems) 30,000 or more 9,000 - 29,999 less than 9,000 Chickens other than laying hens (other than a liquid manure handling systems) 125,000 or more 37,500 - 124,999 less than 37,500 Laying hens (other than a liquid manure handling systems) 82,000 or more 25,000 - 81,999 less than 25,000 Ducks (other than a liquid manure handling systems) 30,000 or more 10,000 - 29,999 less than 10,000 Ducks (liquid manure handling systems) 5,000 or more 1,500 - 4,999 less than 1,5
20. • Preparation of CAFO requirement draft Step 1 • Community input Step 2 • Scientific review Step 3 • Approval by the Green-eⓇ Governance Board Step 4 Main Steps for the Inclusion of CAFOs in Green-e® Renewable Fuel Program PAGE 20 © 2025 Center for Resource Solutions. All rights reserved. CAFOs – Concentrated Animal Feeding Operations
21. • Feedback from Community groups/organizations and contacts • Collected feedback was incorporated into the CAFO requirements draft • Main Outcomes • Only allow for existing CAFOs and exclude expansion of CAFOs • Exclude CAFOs those are in areas with Karst geology • Ban on lagoon-sprayfield systems • Keep Comprehensive Nutrient Management Plans (CNMPs) requirements • If the Green-e® Renewable Fuels program is able to incentivize existing CAFOs to capture methane this will drastically improve the farms’ environmental and community impacts Step 2 – Community Input PAGE 21 © 2025 Center for Resource Solutions. All rights reserved. CAFOs – Concentrated Animal Feeding Operations
22. Extensive review by and discussions with Experts in: • Agronomy • Ammonia Emissions • Hydrology • Hydrogeology Step 3 – Scientific Review PAGE 22 © 2025 Center for Resource Solutions. All rights reserved. CAFOs – Concentrated Animal Feeding Operations
23. PAGE 23 © 2025 Center for Resource Solutions. All rights reserved. CAFOs – Concentrated Animal Feeding Operations CAFO age and size, NPDES and CNMP permits and their disclosures General Lagoon cover and lagoon breech related limitations and disclosures Lagoon Digestate application restrictions Nitrogen Control Testing requirements for surface waters and ground waters Pollutants Testing CAFO Requirements
24. CAFO Requirements – General PAGE 24 © 2025 Center for Resource Solutions. All rights reserved. CAFOs – Concentrated Animal Feeding Operations ➢ The expansion of existing CAFOs and the construction of new CAFOs are not allowed. •A facility must have been first licensed to operate prior to August 6, 2025. No facilities first licensed after that date are eligible. ➢ The facility must obtain and maintain a current National Pollutant Discharge Elimination System (NPDES) permit, even if a NPDES permit is not normally required by state or federal law. •A current Comprehensive Nutrient Management Plan (CNMP) is required as part of the NPDES permit. All sections of the CNMP that describe waste management practices and potential pollution to the surrounding community and environment are required to be available publicly online, and a link to the CNMP from an approved project will be posted on the Green-e® program website. •An initial notice with CRS-approved language and disclosures must be sent to community members (in English and in the primary language(s) of local residents) within a 5-mile radius of the CAFO (including waste or digestate application areas), providing the community with a 45-day period to report anonymous complaints to CRS related to, for example, odors, pollution, water use, and other environmental impacts. ➢ Facilities may not be located in areas with karst geology.
25. CAFO Requirements – Lagoon PAGE 25 © 2025 Center for Resource Solutions. All rights reserved. CAFOs – Concentrated Animal Feeding Operations ➢ Spray field systems (the use of high-pressure equipment to apply or dispose of waste, effluent and/or digestate) are not allowed. ➢ Lagoons that are open to the air (open air waste pits) are not allowed. ➢ Facilities with lagoons for waste storage or digestate liquid that are within 100 feet of a 100-year floodplain, as defined by the Federal Emergency Management Agency (FEMA), are not allowed. A facility without a lagoon that is located in a 100-year floodplain must demonstrate that stored waste will not be impacted and/or breached by flooding. ➢ The facility must disclose to CRS each incident of breach or overflow of lagoon waste within the past 5 years and demonstrate steps taken to prevent future incidents. Significant breaches or overflows of waste may result in disqualification of the facility. ➢ Facilities must have covers over all lagoons. Lagoons must be properly sealed to ensure that no gases are being emitted. If CRS receives complaints or becomes aware of odors in the surrounding communities, CRS may require facilities to perform air monitoring and/or other corrective activities to prevent air emissions and odors.
26. CAFO Requirements – Nitrogen Control PAGE 26 © 2025 Center for Resource Solutions. All rights reserved. CAFOs – Concentrated Animal Feeding Operations ➢ All lagoons that contain manure must be synthetically lined ➢ Digestate applications in the fall or winter, after crops have been harvested, are not permitted ➢ All fields must be sampled prior to digestate application to limit the application to less than the calculated agronomic uptake of the field ➢ The background concentration of nitrogen in the fields must not exceed 15 mg/kg in any 1-foot interval from 0-3 feet ➢ Facilities with tile drains, drain tiles, or other subsurface drain networks are ineligible for digestate land application
27. CAFO Requirements – Nitrogen Control PAGE 27 © 2025 Center for Resource Solutions. All rights reserved. CAFOs – Concentrated Animal Feeding Operations ➢ Fields with nitrogen concentration ranges greater than or equal to 15 mg N/kg as determined by an initial soil test must follow the digestate application criteria and schedule in Table 1 • This table was adapted from Washington State’s regulations on manure application for dairy farms and was recommended to us from a hydrogeologist that works closely with CAFOs • Depending on the range of concentration shown in the left column, the facility would be allowed to apply a certain amount of digestate based on the agronomic rate Source: https://www.centerforfoodsafety.org/files/care-v-dbd- consent-decree_37210.pdf
28. CAFO Requirements – Nitrogen Control PAGE 28 © 2025 Center for Resource Solutions. All rights reserved. CAFOs – Concentrated Animal Feeding Operations • Facilities with less than or equal to 15 mg of nitrogen per kilogram could apply 100% of the agronomic rate year after year • As the concentration ranges increase, the percentage of agronomic rate that facilities are allowed to apply decreases to become more restrictive • Facilities with more than 45 mg of nitrogen per kilogram are not allowed to apply any digestate • The two columns on the right side of the table “Split Application Schedule for Digestate Applied by Irrigation” only apply to crop after year 3 and beyond and split the digestate applications between the fall and spring to limit the amount of application per season • For example, in the nitrogen concentration range of 15.1-25 mg of nitrogen per kilogram, facilities would be able to apply up to 66% of the digestate in the fall and the remainder in the spring Source: https://www.centerforfoodsafety.org/files/care-v-dbd- consent-decree_37210.pdf
29. CAFO Requirements – Pollutants Testing PAGE 29 © 2025 Center for Resource Solutions. All rights reserved. CAFOs – Concentrated Animal Feeding Operations Pollutants nutrients testing Surface Water • A facility that is within 300 feet of surface waters • Testing must be performed on a quarterly basis at a minimum, with a high and low water sampling. A minimum of one upstream and three downstream measurement is required for each facility during each quarterly test. Ground Water Quarterly testing must be done if a facility meets at least one of these four criteria: • High groundwater level / shallow depth to groundwater (the depth threshold may vary depending on site specific conditions, including but not limited to, soil type and drought conditions) • Nearby surface waters that are impaired for nutrients and/or bacteria • Within 100 feet of a floodplain • Within 5 miles of a drinking well (either a domestic well or a community water system)
30. CAFO Requirements – Pollutants Testing PAGE 30 © 2025 Center for Resource Solutions. All rights reserved. CAFOs – Concentrated Animal Feeding Operations Pollutant/Nutrient Groundwater Limits Surface Water Limits Total Nitrogen (N): 6 mg/L 6 mg/L Nitrite 1.0 mg/L 0.5 mg/L Nitrite plus nitrate (mg/L as N) 7.5 mg/L 7.5 mg/L Total Ammonia Nitrogen (TAN)4 at a given temperature and pH 1.9 mg/L TAN at pH 7.0 and temperature 20 °C 1.9 mg/L TAN at pH 7.0 and temperature 20 °C Phosphorous 0.1 mg/L 0.025 mg/L Total Suspended Solids (TSS) 30 mg/L 30 mg/L Fecal coliforms, including Escherichia coli (E. coli) Negative5 235 MPN/100 mL
31. PAGE 31 © 2025 Center for Resource Solutions. All rights reserved. • Renewable Hydrogen • Goal is to accelerate the adoption of renewable hydrogen while ensuring: • Hydrogen is from sustainable renewable sources • Environmental and consumer protection requirements Coming Soon: Green-e® Renewable Fuels Extensions Draft for second public stakeholder comment period: December, 2025 Join the Renewable Hydrogen Stakeholder list if interested in learning more Email rupali.tripathi@resource-solutions.org or matt.altieri@resource-solutions.org
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33. Contact. Rupali Tripathi MANAGER, RENEWABLE FUELS rupali.tripathi@resource-solutions.org resource-solutions.org NOTICE: This presentation is the copyrighted property of Center for Resource Solutions (CRS). It cannot be copied, reprinted or used in any way without permission of CRS. If you wish to obtain permission to use our copyrighted materials, please contact CRS at +1-415-561-2100 or info@resource-solutions.org