The Renewable Natural Gas (RNG) transformation – What’s ... · 10.05.2019 · intended to be,...

© 2019 Eversheds Sutherland (US) LLPAll Rights Reserved. This communication is for general informational purposes only and is not intended to constitute legal advice or a recommended course of action in any given situation. This communication is not intended to be, and should not be, relied upon by the recipient in making decisions of a legal nature with respect to the issues discussed herein. The recipient is encouraged to consult independent counsel before making any decisions or taking any action concerning the matters in this communication. This communication does not create an attorney-client relationship between Eversheds Sutherland (US) LLP and the recipient. Eversheds Sutherland (US) LLP is part of a global legal practice, operating through various separate and distinct legal entities, under Eversheds Sutherland. For a full description of the structure and a list of offices, please visit www.eversheds-sutherland.com.

The Renewable Natural Gas (RNG) transformation –What’s driving investment in biogas projects?

Powering the Future

May 10, 2019Marathon Capital: Scott Chabina Eversheds Sutherland: Susan Lafferty, David McCullough, Ram Sunkara

Eversheds Sutherland / Marathon Capital

Welcome and thank you for joining todaySummary Introductions


Eversheds Sutherland – Summary Overview

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Singled out as the “Best Law Firm” in the RINs Market by Environmental Finance Magazine (2017-2018)

As a global top 15 law practice, Eversheds Sutherland provides legal services to a global client base ranging from small and mid-sized businesses to the largest multinationals.

Eversheds Sutherland provides the full range of legal services, including corporate and M&A; dispute resolution and litigation; energy and infrastructure; finance; human capital and labor law; intellectual property; real estate and construction and tax.

Eversheds Sutherland PRIVILEGED AND CONFIDENTIAL

Eversheds Sutherland in numbers

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offices67

jurisdictions34

people5000

partners700

lawyers2800

countries17

offices35+

countries40+

in our ES LatinAmerican Alliance

in our ES Africa Alliance that form our ESAsia Pacific Alliance

Ranked

12thin the Acritas Global EliteLaw Firm Brand Index 2018

Ranked

12thin Law360’s Global20 firms of 2018

of the FTSE 10066

of the US Fortune 10073

In 2018 we acted for:

of the US Fortune 200119


Marathon Capital: Investment Bankers for Global Energy & Infrastructure Markets

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Marathon Capital – Summary Overview (cont’d)

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The Transformation is already happening:RFS, LCFS Recap


─ Generation 1.0: Various federal and state incentives have fundamentally transformed the transportation fuel market over the past 15 years—driving substantial use of ethanol and biodiesel. These incentives include:• Renewable Fuel Standard (“RFS”)• California Low Carbon Fuel Standard (“LCFS”)• Blenders Tax Credit• Other tax incentives• State and local renewable fuel blend mandates

─ Generation 2.0: The past five years has seen a rapid increase in the use of other renewable fuels as a transportation fuel, particularly biogas (and renewable diesel and renewable electricity). We expect this trend to continue, if not accelerate due to the incentives provided by:• RFS• LCFS• Other state low carbon fuel initiatives (e.g., Oregon’s Clean Fuel Program)

Federal and State Incentives

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─ History: Originally passed in 2005 as part of the Energy Policy Act (“RFS1”); Substantially amended and strengthened in 2007 as part of the Energy Independence and Security Act (“RFS2”)

─ Purpose: Incentivizes/mandates the use of renewable fuel in transportation fuel, heating oil and jet fuel

─ Policy Reasons: 1.Domestic job and industry growth (both

energy and agricultural jobs—notably corn)2. Energy security 3. Reduction in Greenhouse Gas (“GHG”) emissions

─ What Constitutes Renewable Fuel:1. Produced from renewable biomass2.Achieves certain GHG emission reductions3.Replaces volumes of transportation fuel, heating oil

and jet fuel

Renewable Fuel Standard: Background

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RFS: Basic Structure of the Program

─ Requires refiners, importers and component blenders of gasoline and diesel (“Obligated Parties”) to ensure that renewable fuel replaces petroleum-based transportation fuel, heating oil and jet fuel

─ Renewable fuel producers generate credits (“Renewable Identification Numbers” aka “RINs”)

─ RINs can be separated under specified conditions

─ Separated RINs are freely traded

─ RINs are valid for the year in which they are generated and the following year

─ RINs are retired by Obligated Parties and renewable fuel exporters corresponding to the amount of gasoline and diesel they produce or renewable fuel they export

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- Fuel and RIN types RFS Mandates and Fuel Types: 2018 Final Rule

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(Mostly corn ethanol)

(Biodiesel and

renewable diesel)

(Mostly biogas, but also cellulosic renewable diesel and jet fuel)

(Mostly sugarcane ethanol, but also other advanced fuels, such as renewable heating oil and biodiesel/renewable diesel co-processed with petroleum)

Total Renewable Fuel – 19.29 billion gallons (D6 + D3, D4, D5, D7 RINs)

Advanced Biofuel – 4.29 billion gallons (D5 + D3, D4, D5, D7 RINs)

Cellulosic Biofuel – 0.288 billion gallons (D3, D7 RINs)

Biomass-Based Diesel – 2.10 billion gallons (D4 RINs) (approximately 3.3 billion RINs)


- Significant Pressure for Advanced Biofuels and Cellulosic BiofuelRFS Mandates and Fuel Types: 2019 Final Rule

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(Mostly corn ethanol)

(Biodiesel and

renewable diesel)

(Mostly biogas, but also cellulosic renewable diesel and jet fuel)

(Mostly sugarcane ethanol, but also other advanced fuels, such as renewable heating oil and biodiesel/renewable diesel co-processed with petroleum)

Total Renewable Fuel – 19.92 billion gallons (D6 + D3, D4, D5, D7 RINs)

Advanced Biofuel – 4.92 billion gallons (D5 + D3, D4, D5, D7 RINs)

Cellulosic Biofuel – 0.418 billion gallons (D3, D7 RINs)

Biomass-Based Diesel – 2.10 billion gallons (D4 RINs) (approximately 3.3 billion RINs)


Final 2018 and 2019 Standards

RFS CATEGORY VOLUME MANDATE(GALLONS) PERCENTAGE MANDATESTATUTORY VOLUME REQUIREDWITH NO EPA ADJUSTMENTS

(GALLONS)

Total Renewable Fuel 19.29 billion 10.67% 26 billion

Cellulosic Biofuel (D3 & D7) 288 million 0.16% 7 billion

Total Advanced (D3, D4, D5, D7) 4.29 billion 2.37% 11 billion

Biomass-Based Diesel (D4) 2.1 billion 1.74% ≥ 1.0 billion

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RFS CATEGORY VOLUME MANDATE (GALLONS) PERCENTAGE MANDATESTATUTORY VOLUME REQUIREDWITH NO EPA ADJUSTMENTS

(GALLONS)

Total Renewable Fuel 19.92 billion 10.97% 28 billion

Cellulosic Biofuel (D3 & D7) 418 million 0.23% 8.5 billion

Total Advanced (D3, D4, D5, D7) 4.92 billion 2.71% 13 billion

Biomass-Based Diesel (D4) 2.1 billion 1.73% ≥ 1.0 billion

Final 2019 Standards

Final 2018 Standards

- How the volumes are set and the obligations satisfied


─ Foundation is AB 32, Global Warming Solutions Act of 2006 • Goal of AB 32 (as amended in 2016) is to reduce Greenhouse Gas (“GHGs”) emissions by 40%

below 1990 levels by 2030

─ Established through executive order as an AB 32 “Early Action Measure” to reduce GHG emissions from the transportation sector. LFCS reduction of at least 20% in the Carbon Intensity (“CI”) of the state’s transportation fuels by 2030.

─ Annual compliance standard – Carbon Intensity (“CI”) levels reduced incrementally

─ Applies to fuel producers and importers who must meet an annual average CI• Credits can be purchased or generated and retired for compliance

─ Obligations are transferrable by contract• Program designed to keep compliance obligations upstream, but regulated parties may shift

obligations downstream

─ Credits are generated by producing or importing fuels with a lower CI than the annual standards• Unlimited life span

─ Quarterly and annual reporting obligations

California’s LCFS: Background

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Compliance CurvesCalifornia LCFS

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(3.50)-5

-6.25-7.5

-8.75-10

-11.25-12.5

-13.75-15

-16.25-17.5

-18.75-20

-20.0

-18.0

-16.0

-14.0

-12.0

-10.0

-8.0

-6.0

-4.0

-2.0

0.02011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

Perc

ent R

educ

tion

in C

arbo

n In

tens

ity

2011 - 2030 Performance and Future Targets of the Low Carbon Fuel Standard

Historic Compliance Targets (black solid line)

Reported % CI Reduction (green line)

Future Compliance Targets (black dotted line)

Carbon intensities based on composite of gasoline and diesel fuels


Recent Amendments to LCFS

─ Amendments approved Jan 4, 2019

─ California looking to incentivize more credit generation

─ Expected growth of credit generation for RNG due to particularly low CI

─ Expanded “Biomass” definition for eligible sources• Now includes “non-fossilized and biodegradable organic material”• Additionally, “products, by-products, residues and waste” from agriculture, forest

and related industries

─ New opportunities to generate credits on certain fuels• Alternative jet fuel• Carbon capture and storage projects• Renewable/fossil fuel propane

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Observations from Gen 1.0 2.0What are we seeing now? Where is the growth?


What is it?Renewable Natural Gas (“RNG”)

─ Natural gas is predominately methane (chemical formula CH4) originating from underground wells and has historically been produced by the petroleum industry

─ Renewable Natural Gas (“RNG”) is produced from abundant, organic waste materials and is substantially the same as traditional natural gas in composition. RNG is environmentally-friendly, as it captures naturally occurring methane emissions from decomposition of organic material and converts them into beneficial use as fuel

─ Any organic material is a potentially viable source for biogas and RNG production including food waste, garden and lawn clippings, animal- and plant-based material, paper, cardboard, and wood. As long as society creates waste, we will have an abundant source of raw material for RNG production

─ Biogas typically consists of methane and carbon dioxide, with traces of other elements. It is cleaned and conditioned to remove, or reduce, non-methane elements in order to produce RNG. Then it is injected into pipelines as a drop-in replacement for traditional natural gas

─ Following processing and upgrading, RNG is interchangeable with traditional natural gas and can be directly injected into the existing utility natural gas pipelines

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RNG generates tremendous value when used as Transportation Fuels via RFS & LCFS

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Low Carbon Fuel Standard

─ Qualifying Sources:• Any source that produces biogas• Can be produced outside of California

─ Fuel Types:• CNG• LNG• Renewable Electricity

─ End Use:• Transportation Fuel in California

─ LCFS Credit quantity • Dependent on the CI of the individual project as well as the use

of the RNG as a transportation fuel

Renewable Fuel Standard

─ Qualifying Sources:• Landfills (D3 RINs)• Municipal wastewater treatment facility digesters (D3 RINs)• Agricultural digesters (D3 RINs)• Separated municipal solid waste digesters (D3 RINs)• Waste digesters (D5 RINs)

─ Fuel Type:• CNG• LNG• Renewable Electricity

─ End Use:• Transportation Fuel in the United States

─ RIN Quantity:• 1 RIN for every 77,000 BTUs (LHV)• 0.903 (LHV to HHV conversion factor)• 11.72 RINs for every MMBtu

─ RNG now accounts for 95%+ of all D3 RIN production


D3 RIN being the most valuable, owing to its highest GHG reduction requirements

Historical RIN Prices

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Specifically, dairy RNG has the lowest CI Score of any fuel in the marketRenewable Natural Gas (“RNG”)

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Ways to meet the demand for creditsCalifornia LCFS

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CI of Gasoline/Diesel


The transport fuel market is the most lucrative end use for biogas todayRenewable Natural Gas (“RNG”)

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Additionally, RNG qualifies for valuable D3 RINsRenewable Natural Gas (“RNG”)

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Consequently, dairy RNG can be considered the most “valuable” natural gas in the worldRenewable Natural Gas (“RNG”)

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How has the sector been developing?Renewable Natural Gas (“RNG”)

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Where else is RNG being used?Renewable Natural Gas (“RNG”)

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What types of companies are participating in the RNG markets?Renewable Natural Gas (“RNG”)

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Legal and financial considerations in developing or acquiring RNG projects


Key Consideration for Owning/Financing RNG Facilities: RIN and LCFS Credit Validity

─ RIN Validity Risk• RIN generators are liable for RIN and LCFS Credit; this risk can be shared contractually• Mistakes happen• Civil and criminal violations can also lead to RIN invalidity

─ Due Diligence of Ability to Generate Valid RINs and LCFS Credits• Careful review of the pathway for the fuel• Careful review of the background of the individuals• Careful review of compliance systems and generation practices

─ Managing Validity Risk on an Ongoing Basis• Deal structure, financing and ownership provisions• LCFS Credit verification program• RIN QAP Program

• Optional program• Protects the Obligated Parties (i.e., the refiners), not the renewable fuel producers/RIN generators

• Additional RIN generation/compliance systems• RIN insurance (LCFS Credit insurance?)

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─ In order to generate RINs and LCFS Credits, the biogas must be “used” as a transportation fuel

─ This is typically achieved through three or more parties partnering together:• A biogas source (e.g., landfill, wastewater treatment facility)• A natural gas marketer• An end user (CNG/LNG fueling station)

─ One of these parties elects to serve as the RIN generator• A different party can serve as LCFS Credit generator

─ RIN and LCFS Credit revenue is shared between the parties as determined by contract

─ The parties show that the biogas is used as a transportation fuel through:• A physical pathway of connected pipelines (diligence of this pathway is highly recommended)

• Contracts for the sale of biogas and environmental attributes

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Structuring an Agreement to Generate RINs and LCFS Credits on RNG Projects


Structuring an Agreement to Generate RINs and LCFS Credits on RNG Projects

─ Must be used as a transportation fuel • Whether the RNG is actually “used” as a transportation fuel is not always clear cut

─ If injecting into a pipeline:• Pathway/connectivity-risk exposure evaluation• Continuous metering

─ Who will serve as the RIN and LCFS Credit generator• Significant responsibility and liability

─ Sharing the RIN and LCFS Credit revenue• Consider floating, fixed and indexed pricing structures

─ All parties must cooperate and be involved• Knowing your counterparty• Agreements with all parties involved (including sale of the gas)

─ Affidavits from all owners of the biogas─ Existing contracts for environmental attributes─ How much protection do LCFS Credit and QAP Program actually provide?

• Consider additional diligence and validity protections

─ Who to use as consultants/auditors/validators?

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Current RFS Issues

─ PES Bankruptcy and Discharge of RIN Obligations• EPA allowed for significant discharge of a RIN obligation of approximately 250 million RINs

─ RFS Compliance Waivers for Small Refineries• Small refineries must demonstrate to EPA significant economic hardship to receive waiver of RFS

compliance obligation• Between 2013 and 2015, 23 waivers granted• For 2016 and 2017, 54 waivers granted with 2 currently pending; 40 are currently pending for 2018• Current litigation against EPA by the renewable fuels industry

─ Delayed EPA action on small refinery exemption petitions and court rulings resulted in remedy of EPA granting current year RINs that were not specifically tied to renewable fuel production

─ EPA E15/RIN Market Reform Proposed Rule

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How might this impact continued growth / investment in advanced renewable fuels?RFS Reset & Implications on RVOs

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─ The “Reset” of the RFS Volumes• Due to failure of the renewable fuel industry to meet certain volumetric production thresholds, by the end

of this year EPA is required to engage in a resetting of the RFS standards for 2020, 2021 and 2022• Reset based on a variety of factors including impact of renewable fuels on the environment,

infrastructure, consumers job creation, food prices, supply of agricultural commodities, impact on the environment and the expected rate of production of renewable fuel

• In other words, EPA will have significant discretion to set the standards • Proposal at OMB; final rulemaking by November 30, 2019

─ RINs on Renewable Electricity from Biogas and Biomass• Allowed by the RFS, but currently there is no pathway• Lawsuit is currently pending to push EPA to provide for RIN generation• Any allowance would significantly increase the number of RINs in the market

─ RINs on Biogas used as LNG bunker (i.e., vessel) fuel• Possible reading of the RFS would allow for RIN generation on biogas converted to LNG used to power

vessels• With IMO 2020 pending, use of LNG as a bunker fuel will increase significantly• Any such allowance would significantly increase the number of RINs in the market


Will we see further expansion of state-level LCFS programs?Expansion of RNG outside West Coast Markets

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Critical Topics to Examine in Future Webinars / DiscussionsAdditional Considerations and Implications for RNG

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─ Virtual PPAs and Carbon Offset Agreements via RNG • Will the L'Oréal deal serve as a “strawman” for future RNG offtake agreements?• Significant increase in interest levels from corporates and other voluntary markets seeking these

fuels

─ Investor Sentiment / Risk Appetite into Price Curves• NOT appropriate to “bundle regulatory risks” – must be examined individually and priced

accordingly• How are these parties pricing these environmental attributes today? Into the future?• How are contracted offtakes versus spot market exposure viewed by investors?• How are investors thinking about scale in these RNG markets?

Eversheds Sutherland / Marathon Capital 37


Background on the SpeakersMarathon Capital, Eversheds Sutherland


Scott Chabina, Director, Renewable Transportation FuelsMarathon Capital

Speaker Introductions

─ Scott Chabina is Director at Marathon Capital based in New York City with over 14 years of investment banking and financial advisory experience in ethanol and the broader biofuel sectors (advanced biofuels, biodiesel, renewable diesel, RNG). Chabina joins Marathon Capital from Carl Marks Advisors, a nationally recognized corporate restructuring and investment banking firm, where he established and co-led the renewable energy practice and successfully executed multiple engagements representing in excess of 4.0 billion gallons of aggregate production capacity in the ethanol industry alone.

─ Mr. Chabina has successfully advised on mergers and acquisitions, debt and equity capital raises, and complex financial restructuring assignments for companies, secured lenders, and creditors across a wide variety of industries. The breadth of his experience includes renewable energy, specialty chemicals, agriculture, infrastructure, consumer products, retail, healthcare, specialty finance, community banking, building materials, aerospace and defense, specialty foods, media, manufacturing, and automotive.

─ Mr. Chabina’s noteworthy biofuel engagements include, but are not limited to, the following: Abengoa Bioenergy US Holdings LLC (2016 “Sec. 363 Deal of the Year”, $250MM-$500MM category, by the M&A Advisor's "Turnaround Awards"), Metro Fuel Oil Corporation, VeraSun Energy Corporation, BioFuel Energy Corporation, White Energy Corporation, Hawkeye Growth, Choice Ethanol Holdings, and Otter Tail Ag Enterprises.

─ Mr. Chabina was named as a "Top Ten New York Energy Financier" by Breaking Energy (2015), as well to the M&A Advisor's "40 Under 40" (2014). He has served on the Board of Directors of the Turnaround Management Association (NYC Chapter) since 2013.

─ Mr. Chabina earned a BA in Economics from Colgate University and holds his Series 7 and 63 licenses.

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Director,Renewable

Transportation Fuels(212) 204-6336

[email protected]


Susan Lafferty, Partner, Eversheds SutherlandSpeaker Introductions

─ Susan Lafferty advises clients on an array of energy and environmental issues impacting the petroleum, biofuels and energy trading industries. Susan’s extensive practice covers regulatory, commercial and policy issues related to the Renewable Fuel Standard (RFS), Renewable Identification Number (RIN) trading, state Low Carbon Fuel Standards (LCFS), gasoline and Ultra-Low Sulfur Diesel (ULSD) requirements, and shipping all types of commodities by rail, vessel or truck. She also advises clients on daily trading and commercial matters, with a recent focus on biogas/RNG projects.

─ Susan represented more than 15 companies in RIN enforcement proceedings that led to the implementation of the EPA’s Interim Enforcement Policies and Quality Assurance Program “QAP”, as well as refiners and importers facing enforcement actions under the broader mobile source program. Susan led the representation of a renewable fuel trader that EPA alleged exported renewable fuel without retiring RINs. Susan is a sought-after speaker on regulatory and agency actions, is quoted frequently on fuels issues, and co-authored a white paper for the Bipartisan Policy Center entitled “Options for Reforming the Renewable Fuel Standard.”

─ In addition, Susan works with clients to develop risk management and mitigation tools to address potential spills or releases that may occur when transporting and storing products like crude oil, distillates, liquefied natural gas and coal. She has helped her clients navigate crude-by-rail matters, including the new regulatory requirements and responses to some of the largest accidents involving crude oil shipped by rail.

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[email protected] Sixth Street, NWSuite 700Washington, DC 20001


David McCullough, Partner, Eversheds SutherlandSpeaker Introductions

─ David McCullough is a partner in Eversheds Sutherland’s New York office. For over a decade, David has provided legal counsel to producers, refiners, commodity traders and distributors on the production, trade and movement of transportation fuels, both petroleum-based and renewable fuels. David advises on most regulations governing the production and movement of these commodities, but he has a particular focus on the Renewable Fuel Standard (RFS), Renewable Identification Number (RIN) trading, state Low Carbon Fuel Standards (LCFS), the Environmental Protection Agency’s (EPA) mobile source regulatory program, the Jones Act and import and export controls, and shipment by rail and truck.

─ David has a deep understanding of the petroleum market and the regulatory and market forces that impact the sale of gasoline and diesel fuel. He has been at the forefront of representing companies in the implementation and enforcement of the RFS and state low carbon fuel standards. He represented more than 20 companies in RIN enforcement proceedings that led to the implementation of the EPA’s Interim Enforcement Policies and Quality Assurance Program. He is the author of many frequently used provisions in RIN transactions and assisted in the drafting of LEAP’s Master Agreement for LCFS credits. David also co-authored the white paper for the Bipartisan Policy Center entitled “Options for Reforming the Renewable Fuel Standard.” He is a frequent speaker and is quoted extensively in the press on RFS and LCFS issues.

─ Since 2012 when EPA first registered companies to generate RINs on biogas, David has structured and advised clients on dozens of transactions to generate RINs and LCFS credits on the production and subsequent sale of biogas as a transportation fuel. He has provided representation in some of the largest sales and acquisitions of RNG facilities to-date.

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[email protected] Grace Building, 40thFloor1114 Avenue of the AmericasNew York, NY 10036


Ram Sunkara, Partner, Eversheds SutherlandSpeaker Introductions

─ Ram Sunkara serves on the Eversheds Sutherland (US) Executive Committee and focuses his practice on negotiating and finalizing acquisition and disposition agreements, structuring transactions and auction processes, and managing all aspects of a deal. He leads the Natural Gas Liquids (NGLs) and Petrochemical teams and the Distributed Generation and Renewable Corporate Procurement team. Ram also co-leads the Liquefied Natural Gas (LNG) team.

─ Ram represents a broad spectrum of energy sector clients in commercial and transactional matters, including:• Domestic and cross-border mergers and acquisitions• Energy trading arrangements• Joint ventures• Full-scale project development (greenfield and brownfield projects)• Renewable energy projects• Project and structured financings• Develop-Build-Own-Operate-Maintain (DBOOM) and Design-Build-Transfer (DBT) arrangements

─ Ram has extensive experience with the full array of power generation, both traditional baseload generation and renewables/energy storage technologies, including:• Merger and Acquisition Transactions• Power Purchase Agreements (PPAs)• Engineering, Procurement and Construction (EPC) Contracts• Operation and Maintenance (O&M) and Balance of Plant Agreements• Purchase and Sale Agreements for Steam• Chilled Water and other Offtake Contracts• Purchases and sales of environmental attributes (Renewable Energy Certificates (RECs), Renewable Identification Numbers (RINs), etc.)• Trading agreements involving both physical and financially settled purchases (including secured and unsecured hedges) and sales of

electric power and related products

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[email protected] Fannin StreetSuite 3700Houston, TX 77002

eversheds-sutherland.com© 2019 Eversheds Sutherland (US) LLPAll rights reserved.

Powering the FutureWelcome and thank you for joining todayEversheds Sutherland – Summary OverviewEversheds Sutherland in numbersMarathon Capital: Investment Bankers for Global Energy & Infrastructure MarketsMarathon Capital – Summary Overview (cont’d)The Transformation is already happening:Federal and State IncentivesRenewable Fuel Standard: BackgroundRFS: Basic Structure of the Program RFS Mandates and Fuel Types: 2018 Final RuleRFS Mandates and Fuel Types: 2019 Final RuleFinal 2018 and 2019 StandardsCalifornia’s LCFS: BackgroundCalifornia LCFSRecent Amendments to LCFSObservations from Gen 1.0 2.0Renewable Natural Gas (“RNG”)RNG generates tremendous value when used as Transportation Fuels via RFS & LCFSHistorical RIN PricesRenewable Natural Gas (“RNG”)California LCFSRenewable Natural Gas (“RNG”)Renewable Natural Gas (“RNG”)Renewable Natural Gas (“RNG”)Renewable Natural Gas (“RNG”)Renewable Natural Gas (“RNG”)Renewable Natural Gas (“RNG”)Legal and financial considerations in developing or acquiring RNG projectsKey Consideration for Owning/Financing RNG Facilities: RIN and LCFS Credit ValidityStructuring an Agreement to Generate RINs and LCFS Credits on RNG ProjectsStructuring an Agreement to Generate RINs and LCFS Credits on RNG ProjectsCurrent RFS IssuesRFS Reset & Implications on RVOsExpansion of RNG outside West Coast MarketsAdditional Considerations and Implications for RNGSlide Number 37Background on the SpeakersSpeaker IntroductionsSpeaker IntroductionsSpeaker IntroductionsSpeaker IntroductionsSlide Number 43

The Renewable Natural Gas (RNG) transformation – What’s ... · 10.05.2019 · intended to be,...

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