WIN WITH RINS: Overview of the RFS2 Regulation and New Opportunities for Biogas Producers
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1 WIN WITH RINS: Overview of the RFS2 Regulation and New Opportunities for Biogas Producers April 21, 2015 Luca Nencetti, Associate First Environment, Inc.
2 About First Environment HQ in NJ with regional offices across U.S. Third-party verification services Climate change technical assistance Regulatory support Site investigation and remediation Environmental due diligence Voted Environmental Finance s Best Verifier for North American Markets 2008 through landfill projects involving GHGs or RFS2 2
3 Presentation Roadmap Introduction to RFS2 and RINs Economic opportunities for biogas producers Achieving registration Guide to the engineering review Quality Assurance Program for RINs verification 3
4 INTRODUCTION TO RFS2 & RINS
5 EPA s Renewable Fuel Standard Mandates minimum volume of biofuels in U.S. transportation fuel supply each year Target: 36 billion gallons by 2022 Establishes standards for fuel suppliers and RIN tracking system Suppliers have annual renewable volume obligations (RVOs) One RIN = one gallon of ethanol 5
6 Renewable Identification Numbers RINs are: Only generated from qualifying feedstocks, fuel pathways (D code) Reported to EPA by producer or importer Can be sold or transferred to be used for RVOs (with fuel or separated) 6
7 ECONOMIC OPPORTUNITIES FOR BIOGAS PRODUCERS
8 Renewable Natural Gas Pathways Pathway Fuel type Q T Renewable CNG Renewable LNG Renewable Electricity Renewable CNG Renewable LNG Renewable Electricity Feedstock Biogas from: landfills municipal wastewater treatment facility digesters agricultural digesters separated MSW digesters cellulosic components of biomass processed in other waste digesters Production Process D-Code Any 3 Biogas from waste digesters Any 5 Title 40 CFR Part Table 1 8
9 Biogas Project Characteristics Biogas produced from: Landfills Wastewater treatment plants Anaerobic digesters Transportation End User: CNG/LNG (High Btu RNG) Electricity used for on-road transportation (Medium or High Btu Biogas) Biogas production and end user can be different entities in different geographic locations 9
10 Requirements for Biogas CNG/LNG/Electricity Pathways Biogas is the feedstock CNG/LNG/electricity is the renewable fuel Producer (RINs generator) can be any party in project chain Biogas producer Biogas treatment plant Gas marketer CNG/LNG/electricity processor or distributor 10
11 Value of D3 and D5 RINs 77,000 Btu of CNG/LNG = 1 EGE RINs/MMBtu CNG/LNG 5.86 RINs/Mscf LFG 22.6 kwh of Renewable Electricity = 1 EGE 4.90 RINs/MMBtu LFG 2,000 Mscf/day LFG ~ 1,000 MMbtu/day 4.2 Million RINs/year EGE = ethanol gallon equivalent LFG ~ 500 Btu/scf 11
12 Value of D3 and D5 RINs D5: $0.80/RIN ~$9.00/MMBtu D3: $ $1.40/RIN ~$ $15.75/MMBtu Natural Gas price ~ $2.50 $3.50/MMBtu $1.40 $1.20 $1.00 $0.80 $0.60 $0.40 $0.20 $- D5 RIN Price Trend
13 ACHIEVING REGISTRATION
14 Registration Process 14
15 Registration Process Stage RFS2 application Engineering review EPA review and approval Estimated Time Frame for Completion 8-12 weeks, depending on data availability and project complexity 4-6 weeks, depending on data availability and number of facilities/site visits No less than 8 weeks from submission, dependent on EPA load and project complexity 15
16 Requirements for Registration List of feedstocks, fuels produced Description of production process Types of co-products produced Process heat fuel supply plan Baseline volume calculations and supporting records Records of contractual pathway: source to end user Evidence of physical pathway: source to end user Third party engineering review report 16
17 Landfill (Biogas Source) Contractual Pathway - CNG/LNG/Electricity Commercial Pipeline Fleet Manager (End User) Treatment Plant LNG/CNG Production Facility Track biogas through end user; affidavits if contracts unavailable Demonstrate fuel used for transportation purpose only, no other party relied on volume for RIN generation Provided at time of registration, plus ongoing recordkeeping 17
18 Physical Pathway Commercial Distribution Evidence gas is injected into commercial pipeline (e.g., sales invoices, nomination records, etc.) Description of modalities of transportation of fuel from production to conversion facilities (e.g., physical pipeline pathway) Transportation route, network, pipeline maps Nomination records or sales invoices Contracts 18
19 GUIDE TO THE ENGINEERING REVIEW
20 Overview of the Engineering Review Verifies accuracy of registration data Performed by licensed Professional Engineer Independent from fuel producer Requires site visit and records review 20
21 Site Visit Requirements Landfill (Biogas Source) Commercial Pipeline Fleet Manager (End User) Treatment Plant Site visits required up to pipeline injection Document review to confirm site visit observations, confirm RFS2 requirements met LNG/CNG Production Facility Requirements evaluated through documents review, additional site visits optional 21
22 Common Pitfalls in Registration Contract arrangements not complete Process Fuel use not clearly designated Inadequate documentation of physical pathway Limited production data available 22
23 QUALITY ASSURANCE PROGRAM FOR RINS VERIFICATION
24 Incentives for Verification Note: RIN verification is voluntary Addresses concern of invalid RINs Standardized audit process Increases value of RINs Promotes greater liquidity in transfer/use of RINs 24
25 QAP-Q Requirements Performed by independent, EPAapproved third party verifier Periodic monitoring of fuel production Periodic on-site audits Audit requirements can be reduced if continuous monitoring is implemented 25
26 Summary Despite past market volatility, value of biogas RINs appears to be well-supported EPA has improved and streamlined registration process for biogas projects QAP-Q verifications allow for increased market transparency and RIN value 26
27 For More Information Contact us: Luca Nencetti, Associate First Environment, Inc. 79 Madison Avenue, 2 nd Floor New York, NY x301 lnencetti@firstenvironment.com 27
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