Over the past five years, Center for Resource Solutions (CRS), the NGO that administers the Green‑e^® certification programs, has focused on developing a set of requirements under the Green‑e^® Renewable Fuels program for Concentrated Animal Feeding Operations (CAFOs) producing biofuels, to address environmental and community impacts from CAFOs that produce fuel used in Green‑e^® certified sales. This effort culminated last year in the release of updated Renewable Fuels Standard with CAFO requirements listed in Appendix A. As part of broader program alignment, there was also an initiative to ensure consistent treatment of CAFO-derived resources across both the Green‑e^® Energy and Renewable Fuels standards.

The most recent version of the Green‑e^® Renewable Energy Standard for Canada and the United States (“Energy Standard”) requires that CAFOs producing biomethane adhere to the Green‑e^® Renewables Fuels CAFO rules; currently, CAFOs producing biogas (that has not been upgraded to biomethane) are not required to meet the same rules as biomethane.

The next step in consistent treatment of CAFOs across Green‑e^® programs would be to to require that CAFOs producing biogas also follow the Green‑e^® Renewable Fuels CAFO criteria. This survey is meant to collect feedback on this potential change.

The proposed change to the Energy Standard is to update Section II.A.5.c.i to read (additions underlined):

“Biomethane and/or biogas from Concentrated Animal Feeding Operations (CAFOs), as defined in the Green‑e^® Renewable Fuels Standard (Fuels Standard), that is not delivered to a common carrier pipeline must demonstrate compliance with the following sections of the Fuels Standard in order to be used in a Green‑e^® Energy certified product: Feedstocks for Anaerobic Digestion; Carbon Intensity; Fuel Transport; Regulatory Surplus; Double Counting; and Appendix A.”

For background on development of the CAFO criteria in Green‑e^® Renewable Fuels and to view the CAFO requirements, see Biomethane from Animal Waste: Updates to the Green‑e^® Renewable Fuels Standard.

Comments will be accepted through this survey until 11:59pm Pacific Time on Monday July 6, 2026.