Regulatory Submissions

At the end of November, APGA submitted comments to the World Resources Institute (WRI), which is updating their Greenhouse Gas (GHG) Protocols. These are widely used by many in the energy supply chain. APGA, along with like-minded stakeholders the RNG Coalition and NGVAmerica, all provided similar input responding to proposed changes in Annex B: Biomethane. Renewable natural gas (RNG) and clean hydrogen are an important near-term decarbonization strategy for existing instances where geologic natural gas is utilized; and in the long-term, their use will be necessary for applications that cannot be fully electrified, especially given reliability requirements. RNG is one of the few energy sources that can directly substitute for geologic natural gas and thus lower emissions, utilizing existing infrastructure.

In the submission, APGA expressed concern that the proposed language contained specifically in Part 2, Annex B is premature. Publishing now will hinder our country’s GHG reduction goals, runs counter to existing precedent, and does not consider project development trends. APGA urged WRI to remove the current changes until a robust stakeholder process has been conducted to determine the appropriateness and any potential limitations.