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Green-e® Energy Standard CAFO Language Update

Over the past five years, 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 Green-e® 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.
1.Do you support making this proposed change to the Green-e® Energy Standard? Please provide an explanation in the comment box below.
2.If the proposed change were implemented, how would if affect your business? Please provide an explanation in the comment box below.
3.Please provide any feedback on the clarity or scope of the proposed language, including whether it should apply to biogas from CAFOs, or any other comments to support you choice on the previous questions.
4.If the proposed change is adopted, what should CRS consider during implementation? (For example: timing to begin enforcement; verification procedure). Please provide your suggestions, rationale and proposed details.
5.Currently, the Oregon Clean Fuels Program (CFP) requires that qualifying electricity from CAFO biogas purchased for CFP compliance be Green-e® Energy certified. The proposed change to the Green-e® Energy Standard would affect CAFOs generating this electricity. Is your primary concern with the Green-e® CAFO requirements that they would affect participation in external programs (e.g., the Oregon CFP)?
6.If you answered yes to the previous question, would the proposed change to the Green-e® Energy Standard negatively impact you if the Oregon CFP and other external programs did not require sales of electricity from CAFOs to be Green-e® Energy certified?
7.The CAFO requirements implemented in Green-e® programs were designed to address environmental and community impacts associated with CAFOs that produce fuel for Green-e® Renewable Fuels certified sales. In some cases existing state or jurisdictional regulations do not fully address these concerns.

Do you believe that compliance with current state or jurisdictional regulations may be sufficient to address environmental and community impacts associated with CAFOs? If so, how should entities demonstrate that their CAFO operations are not adversely affecting the environment or surrounding communities?
8.If you have any additional feedback, please provide below: