Alternative Measurement Protocols for Biogas and Renewable Natural Gas

The Renewable Fuel Standard regulations require that biogas and renewable natural gas used to produce renewable fuels must be measured using methods specified in the regulations under 40 CFR 80.155(a)(1) or (2) or using an EPA-approved alternative measurement protocol (AMP) under 40 CFR 80.155(a)(3). The table below lists AMPs approved by the EPA and the requirements for use.

To use an EPA-approved AMP, interested biogas and RNG producers must submit the information described under 40 CFR 80.135(c) or (d), as applicable, as part of their registration submissions. Producers must specify the AMP flowmeter type and submit all of the following related information¹:

(A) A description of why they are unable to use meters that comply with the requirements specified in § 80.155(a)(1) and (2), as applicable.

(B) A description of how measurement is conducted including any applicable standards with the measurement description (e.g., see table below).

(C) Any standards or specifications that apply (see table below).

(D) A description of all routine maintenance and the frequency that such maintenance will be conducted.

(E) A description of the frequency of all measurements and how often such measurements will be recorded under the AMP.

(F) A comparison between the accuracy, precision, and reliability of the AMP and the requirements specified in § 80.155(a)(1) and (2), as applicable, including any supporting data including the applicable standards with accuracy, precision, and reliability specifications (e.g., see table below).

The table below replaces the previous table of approved Alternative Measurement Protocols for Biogas and Renewable Natural Gas which listed EPA determination letters by company. If you are a company with an approved EPA determination, it is still in effect (refer to the archived version of this page). EPA does not plan to issue company-specific determination letters going forward. For each flowmeter type, all corresponding standards and requirements must be met.

Note 1: See 40 CFR Part 80 Subpart E 80.135(c)(3)(iii) or 40 CFR Part 80 Subpart E 80.135(d)(3)(iii), as applicable.