Renewable Carbon Testing in Regulations & GHG Initiatives

  • California SB32 Mandatory GHG Emissions Reporting (Read More)

ASTM D6866 is used to measure the percentage of carbon-neutral CO2 emissions from the combustion of biomass, municipal solid waste, or waste-derived fuels with biomass.

SB32 builds off of AB32 which set emissions goals from 1990 to 2020 and allows fuel sampling in lieu of emissions sampling as long as (a) the fuel is supported by ASTM D6866, and (b) the samples collected for analysis are representative of the entire composition of the fuel. SB32 sets emissions reduction goals of 40% below 1990 levels by 2030.

  • European Union Emissions Trading System (EU ETS) (Read More)

The EU ETS recommends EN ISO 21644:2021 for measuring the biomass fraction of solid recovered fuels. For liquid samples and CO2 in flue gases, EN ISO 21644’s Carbon-14 method or ASTM D6866 can be used. ISO 13833 is another option for CO2 in flue gases.

  • UK Emissions Trading Scheme (UK ETS)

The UK Emissions Trading Scheme (ETS) started in 2021 to replace the UK’s participation in the EU ETS. Since the UK was a member of the EU when the EU ETS was developed and contributed to its creation, the UK ETS was designed to provide continuity for regulated entities which participated in the EU ETS prior to 2021.

The program’s rules on biomass allow biogenic emissions to be subtracted from total lifecycle emissions. Regulated entities are recommended to demonstrate compliance by providing biogenic content testing following either ASTM D6866 or ISO 13833.

UK Emissions Trading Scheme (April 2023)
UK Emissions Trading Scheme (UK ETS): monitoring and reporting biomass in installations (November 2021)

  • Western Climate Initiative (WCI) Requirements of Mandatory Reporting (Read More)

Owners/operators of general stationary combustion units using mixed fuels and waste-derived fuels are mandated to use ASTM D6866 to determine the biomass-derived fraction of their carbon dioxide emissions.

  • US EPA Final Mandatory GHG Reporting Rule (Read More)

ASTM D6866 is used to determine the biogenic CO2 of emissions from the combustion of municipal solid waste and mixed fuels (biogenic and non-biogenic fuels).

  • UN CDM Methodology ACM0022: “Large-scale Consolidated Methodology – Alternative waste treatment processes” (Read More)

ASTM D6866 testing is done to measure the fraction of fossil carbon in the total carbon content of municipal solid waste.

  • The Climate Registry Protocols

The Climate Registry aims to establish consistent, transparent standards throughout North America for businesses and governments to calculate, verify, and publicly report their carbon footprints in a single, unified registry.

When calculating emissions from waste fuels and biomass, ASTM D6866 testing is required.

Sources: Pages 35-36 of TCR’s General Reporting Protocol Version 3.0 (May 2019)

Local governments are required to identify and report biomass CO2 emissions as biogenic emissions, separate from fossil fuel emissions. ASTM D6866 is recommended when measuring biogenic emissions from biofuels, waste fuels, and biomass co-firing in a unit with CEMS.

Source: Page 84 for TCR’s Local Government Operations Protocol Version 1.1 (May 2010)

ASTM D6866 is the method identified for partitioning anthropogenic and biogenic CO2 emissions in the TCR Electric Power Sector Protocol for the Voluntary Reporting Program.

Source: Page 46 for TCR’s Electric Power Sector Protocol Version Version 1.0 (June 2009)

  • Australia Department of the Environment and Energy National Greenhouse and Energy Reporting Scheme

The National Greenhouse and Energy Reporting Act 2007 established a mandatory reporting system for corporate GHG emissions and energy production and consumption. The first reporting period under the Act commenced in July 2008.

In the NGER reporting system, ASTM D6866 analysis is recommended to determine the amounts of each kind of fuel in blended liquid or solid fuels.

Source: Chapter 2.6-Blended Fuels National Greenhouse and Energy Reporting (Measurement) Determination 2008 Compilation No. 14 (July 2022)

  • Environment and Climate Change Canada Greenhouse Gas Reporting Program (GHGRP)

Since 2004, the GHGRP has collected greenhouse gas emissions data from facilities across Canada that emit 10 kilotons or more of GHGs in carbon dioxide equivalent units per year. These facilities are required to submit their report by June 1.

Under the program’s Greenhouse Gas Quantification Requirements, ASTM D6866 testing can be used to determine the biogenic portion of CO2 emissions. If combusted fuels or fuel mixtures contain a biomass fraction that is unknown or cannot be documented (e.g., tire-derived fuel), ASTM D6866 testing is conducted on the representative fuel or exhaust gas samples at least every three months. If municipal solid waste is combusted, ASTM D6866-16 analysis is performed on the exhaust gas stream.

Source: Page 19 of Canada’s Greenhouse Gas Quantification Requirements Version 5.0 (December 2021)

  • New Zealand Climate Change Regulations

The New Zealand Government has 2 regulations incorporating ASTM D6866.

Under the Climate Change (Stationary Energy and Industrial Processes) Regulations 2009 (SR 2009/285), those who will opt to use the continuous emissions monitoring method for calculating emissions from combusting used oil, waste oil, used tyres, or waste will measure their total annual emissions consisting of non-biomass CO2, CH4, and N2O. According to the regulation, ASTM D6866 will be used to measure the non-biomass fraction of CO2 emissions when the fuel combusted contains both biomass and non-biomass.

Those who will use the periodic source testing method will also measure the same greenhouse gas emissions. The non-biomass fraction of the total CO2 emissions is determined in accordance with ASTM D6866.

Source: SR 2009/285

For the Climate Change (Unique Emissions Factors) Regulations 2009 (SR 2009/286), specifically under the “requirements for applications for unique emissions factor approval for waste calculated using standard testing option,” ASTM D6866 can be used by a waste combustion participant to calculate a unique emissions factor for solid fuels.

Under “sampling and testing requirements for the periodic source testing option,” waste combustion participants using mixed fuel (biomass with non-biomass) have to measure the non-biomass fraction of the CO2 concentrations in the gas stream in accordance with ASTM D6866.

Source: SR 2009/286

  • Germany’s Fuel Emissions Trading Act (BEHG)

The Brennstoffemissionshandelsgesetz (BEHG) is Germany’s national emissions cap program. A 2023 ordinance on emissions testing has prompted the BEHG to recognize the biogenic portion of emissions from waste incineration. ISO 13833 is one of the analytical standards cited for carbon-14 testing flue gases.

Source: Page 94 – Leitfaden zur Erstellung von Überwachungsplänen und Emissionsberichten für stationäre Anlagen (June 2023)

Programs Recommending Carbon-14 Method

  • UK Office of Gas and Electricity Markets (OFGEM)

Electricity and gas market regulator OFGEM approves the use of the carbon-14 method for biofuels producers seeking to claim Renewable Obligation Certificates (ROCs). The carbon-14 method is used to determine the renewable energy content of fuels produced from biomass or waste feedstocks by post-combustion analysis of flue gases. For more information interested parties should refer to OFGEM’s most recent guidance on Renewables Obligation Fuel Measurement and Sampling.

Source: Renewables Obligation: Fuel Measurement and Sampling (April 2020)

  • Global Cement and Concrete Association’s Cement CO2 and Energy Protocol

The Cement CO2 and Energy Protocol requires the use of international standards (e.g. EN ISO 21644)  to determine the biogenic carbon in mixed fuel’s overall carbon content. The document is aimed at engineers and managers of cement producers. It was developed in 2019 by the Global Cement and Concrete Association and the European Cement Research Academy, building on the work carried out by the World Business Council for Sustainable Development’s Cement Sustainability Initiative (WBCSD CSI).

Source: Page 92 of Protocol Version 3.1 (February 2020)

Page last updated: August 2023