Dena verifications - Storage of GHG values in the company audit

In Biomethane, JIT, GHG by agriportance GmbH

The role of the dena biogas register in climate protection 

The dena (German Energy Agency) biogas register plays a central role in providing evidence in the electricity and heating market. In 2018, the European Union set itself the goal of reducing greenhouse gas emissions and increasing the use of renewable energies in the Renewable Energy Directive (RED II). Laws such as the Renewable Energy Sources Act (EEG) were passed to implement these climate targets at national level. This regulates the remuneration of electricity from sustainable sources, such as biomethane. The EEG also places requirements on electricity generation, in particular the complete provision of evidence. To this end, the biogas register was set up in Germany as a central register for recording and transferring guarantees of origin, the legal basis for which is set out in the dena Biogas Register Guide is noted. In addition to the biogas register, Nabisy (Sustainable Biomass System) is another register. Nabisy and dena have a certain overlap, but mainly cover emissions trading. 

What are dena certificates and why are they important? 

The Biogas Register (BGR) is a platform for the documentation and dissemination of guarantees of origin for biomethane that are used in the Renewable Energy Sources Act (EEG) or the Building Energy Act (GEG). There is also the Nabisy register for sustainability certificates that are required to comply with other laws such as the GHG quota or the Fuel Emissions Trading Act (BEHG). 

Plants that produce electricity for the EEG or heat for the GEG are obliged to have the previous year's biomethane quantities certified by February 28 at the latest. 

Recording the data in the dena system

In order to record biomethane quantities, registry participants must first enter the relevant installation in the system. They then initiate a plant audit (AAD), which serves to check the plant information. Once the plant audit (AAD) has been successfully confirmed, production batches (PC) can be entered into the biogas register. It is possible to enter PC either during the year or at the beginning of the following year.

At the beginning of the following year, the booked-in PCs are subjected to an operational audit (BAD). This audit serves to verify the quantities fed into the grid and to check compliance with legal requirements, such as mass balancing. The operational audit is based on a standardized catalog of criteria that sets out specific requirements for the legal framework, including the EEG, GEG and BEHG. The dena Biogasregister product matrix and the dena Biogasregister criteria catalog support the assignment of the respective criteria to the biomethane quantities. When creating the BAD, the applicable criteria can be selected from a list and assigned to the PC. Both the auditor and the registry administration must confirm the PC with the assigned criteria and thus set it to green. There is also the option of setting quantities to yellow, which allows separate marketing of guarantees of origin and biomethane. However, this procedure is not permitted under German legislation and is only used abroad or to achieve voluntary targets. 

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Documentation of the GHG value 

In addition to the standardized criteria, it is also possible to have so-called verification-relevant comments accepted. For example, some customers request the certification of a GHG value. This information gives traders the flexibility to also sell to other European countries. 

By adding a "free substrate criterion", you have the option of specifying a GHG value (greenhouse gas value) for a specific PC or splitting the PC and storing different GHG values for the respective partial quantities. This enables a flexible and precise transfer of GHG values along the value chain. You should pay particular attention to the correct specification of the GHG value. This is done in g CO2eq/kWh and not in g CO2eq/MJ. The distinction comes from the electricity sector, where calculations are made in kWh, and the emissions trading and transportation sector, where MJ are used. In addition, a description such as "EVK1 (020204)" can be added to further specify the documentation. 

Alternatively, you can pass on the GHG value via a delivery bill for intermediate products (Proof of Sustainability, PoS). A major disadvantage of the PoS is that the dena criteria are not shown on the PoS and, unlike in the dena biogas register, are only checked at a later date as part of recertification. For this purpose, the PoS is linked to the proof of origin, as described in the next chapter. 

Figure 1: The "Add free substrate criterion" field under the "Substrate criteria" tab to have the GHG value certified.  
Figure 2: Example of a free substrate criterion. 

Parallel verification 

A careful approach is required to ensure the parallel use of guarantees of origin and sustainability certificates and to rule out double marketing. If a PC is used both for the EEG or the GEG and for the BEHG, it may be necessary to maintain the proofs in parallel in Nabisy and in the biogas register. 

In order to link biomethane certificates of origin from the dena biogas register (BGR) with the sustainability certificates in Nabisy, it is crucial to include the plant number of the last interface and the relevant verification numbers in the plant criteria to be checked in good time before the audit as part of the dena plant audit (BAD). 

dena and the BLE are working on an interface between the systems, which would allow the data to be reconciled automatically. However, until these efforts are finalized, the simultaneous transmission of certificates of origin and sustainability certificates is the recommended procedure to prevent double marketing. 

Figure 3: The "Add verification-relevant comment" field under the "Verification criteria" tab, as shown here for linking the verification with one or more Nabisy sustainability verifications. 

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