APGA Submits Comments to CRS on RNG Standard and Certification Program

By Stuart Saulters posted 11-05-2020 11:08 AM

On October 30, APGA submitted comments to the Center for Resource Solutions (CRS), which is developing a new Green-e standard and certification program for renewable natural gas (RNG). This work is precedential, so it is valuable for APGA to engage. APGA is appreciative that CRS is developing this standard, which provides requirements for the certification of renewable gas production, sales, and consumption. With this, more stakeholders in the end use energy market will consider RNG. However, there are concerns with the direction this initiative is going.

APGA participated in the first, open comment period. Unfortunately, after reviewing the redline summary of changes to the standard, which were developed from input from APGA and others, it appears the current effort is deviating from the original intent and may result in a deliverable many natural gas distribution companies will not even utilize. It was important to add input into this second comment period.

In its comments, APGA noted that CRS has included irrelevant information on building electrification in the standard and certification program. In fact, it seems to promote building electrification through disclosure requirements. All forms of energy have a role to play in achieving our country’s environmental goals, so endorsing one does not seem appropriate, especially for an initiative on RNG. As well, CRS is considering limiting the standard and certification program to include only large commercial and industrial customers. The comments responded that limiting to such a small subset of eligible participants, and excluding residential customers, is neither appropriate nor warranted. APGA asked CRS to allow residential and small commercial customers to participate, in addition to the large commercial and industrial ones. Residential customers prefer gas, so there is significant potential for RNG.

Finally, APGA requested that the standard and certification program not include a minimum monthly purchase amount for any customer group. The renewable gas market for thermal applications is still early in the development phase. Both production and demand are just starting to “ramp up,” so CRS should not place an arbitrary minimum purchase. Given the typically smaller size of APGA member systems, these utilities, more than any others, would likely not participate in the standard if there is a high minimum requirement.

APGA is hopeful CRS will take this feedback and ensure the Green-e standard and certification program meets the original purpose, ensuring America’s pipeline infrastructure and trained workforce is used in achieving our country’s clean energy future. By submitting comments, APGA also let CRS know the association and its members are critical to the natural gas value chain, and this input needs to be considered. APGA is working with several other groups in responding to CRS, including the American Gas Association (AGA), the American Biogas Council, the Coalition for Renewable Natural Gas and the Business Council for Sustainable Energy.

To see the attached final comments submitted, click here.

For questions on this article, please contact Stuart Saulters of APGA staff by phone at 202-544-1334 or by email at ssaulters@apga.org.