The Biogas Regulatory Reform Rule (BRRR) marks a pivotal update to the Renewable Fuel Standard (RFS) program. This regulatory shift is designed to streamline the framework for biogas production, enhancing its marketability within the renewable energy sector. By expanding the scope of obligated parties and refining compliance requirements, the BRRR aims to foster greater efficiency and transparency in the biogas industry.
Expanded Scope of Obligated Parties
With the introduction of the BRRR, the scope of obligated parties under the RFS program has been significantly expanded. Now included are:
– Biogas Producers: Entities that generate biogas from renewable biomass.
– Importers of Biogas: Parties responsible for importing biogas into the U.S. market.
– Marketers and Distributors of Biogas: Those who market and distribute biogas.
– Blenders of Biogas: Organizations that blend biogas with other fuels.
Compliance and Reporting Requirements
The BRRR introduces new compliance and reporting obligations for the expanded list of obligated parties. Key requirements include:
– Record-Keeping: Parties must maintain detailed records of Product Transfer Documents (PTDs).
– Reporting: Monthly, quarterly, and annual reports are required.
– Audits: All parties will be subject to audits to ensure compliance.
Registration with the EPA
Biogas producers, RNG producers, and RNG RIN separators must register with the Environmental Protection Agency (EPA). This registration requires demonstrating that facilities produce biogas, RNG, or CNG/LNG from renewable biomass in accordance with EPA regulations.
Specific Requirements for Biogas and RNG Producers
Under the BRRR, specific requirements include:
– Submission Information: Parties must report feedstock usage, conversion processes, and additional compliance details.
– Entity Identification: Biogas and RNG producers must disclose their business partners, with the EPA tracking these relationships in the EMTS. All associated entities are held liable for each other’s actions.
RIN Generation Requirements
To generate Renewable Identification Numbers (RINs), parties must:
– Demonstrate RNG Withdrawal: Show that RNG has been loaded and withdrawn from a natural gas distribution system.
– Match CNG/LNG Sales: Ensure that the amount of CNG/LNG sold as transportation fuel matches the RNG placed on the system.
Defining New Obligated Parties
The BRRR clarifies the roles of new obligated parties:
– Biogas Producers: Entities that own or operate biogas production facilities using renewable biomass.
– RNG Producers/Importers: Facilities that upgrade biogas to RNG or import RNG. Only foreign RNG producers or domestic importers may generate RINs.
– RIN Separators: Parties that withdraw RNG from pipelines, produce CNG/LNG from RNG, or dispense RNG as transportation fuel.
Important Date
– Starting January 1, 2025, all parties must comply with the new BRRR regulations.
How RINSTAR Can Help
Navigating the BRRR can be complex, but RINSTAR is here to assist. As a leading consulting service specializing in RIN management, RINSTAR offers tailored support to help new obligated parties meet their compliance and reporting requirements.
RINSTAR provides expert advice on understanding and implementing the BRRR’s requirements. Whether you need help with CDX registration, compliance, or reporting, our team of professionals offers clear, actionable guidance to ensure you meet all regulatory standards.
RINSTAR Services include:
– Record-Keeping: Assistance with maintaining and organizing Product Transfer Documents (PTDs). These are automatically generated and sent out to your Trading Partner upon transaction approval.
– Reporting: Support in preparing and submitting the necessary monthly, quarterly, and annual reports. RINSTAR keeps our thumb on the pulse of the ever-changing reporting requirements doled out by the EPA.
RIN Management
RINSTAR helps with the management of Renewable Identification Numbers (RINs), ensuring accurate generation and reporting. Year to date, RINSTAR clients have successfully generated 248,237,403 RINs!
Personalized Support
For specific needs or complex situations, RINSTAR offers personalized consulting services. Our team works closely with clients to address unique challenges and develop customized strategies for effective compliance. Our helpdesk is staffed Monday through Friday, and has a reputation for speedy responses and resolutions.
By leveraging RINSTAR’s expertise and resources, obligated parties can effectively navigate the BRRR, ensuring compliance and capitalizing on new opportunities within the renewable energy sector.
