SUBJECT
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Authorizing the City Manager to amend the Renewable Natural Gas (RNG) fuel credit contract with Clean Energy approved on September 3, 2024. The EPA has released new regulations, referred to as the Biogas Regulatory Reform Rule (BRRR), that become effective January 1, 2025. These regulations apply to anyone producing, delivery, or using RNG at a CNG station, and are creating additional roles and responsibilities throughout the RIN lifecycle (Biogas Producer > RNG Producer > RIN Owner > RIN Separator). Essentially, EPA is trying to get all parties in the RNG value chain to take on a more active role in the RFS program. This new regulation affects the recently executed RNG Supply contract, but will not affect the payment or any other terms of the contract.
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PREVIOUS COUNCIL ACTION
Council approved the execution of the Renewable Natural Gas (RNG) contract on 09/03/2024.
BACKGROUND
CNG station owners fall under the "RIN Separator" category. The RIN Separator is responsible for receiving RINs from the RIN Owner/RNG Producer, completing monthly separations and remittance activities, and submitting quarterly RFS reports and annual attestations. All this will be performed via EPA's Central Data Exchange (CDX) and EPA Moderated Transaction System (EMTS) systems. The first step to this is registering El Metro's fueling station and submitting Alternative Measuring Protocols (AMPS.)
While this sounds like a lot (it is), fortunately, Clean Energy is El Metro's RNG supplier and will comply with the RIN Separator criteria and can assume the RIN Separator role at El Metro's station. Clean Energy will continue delivering RNG to El Metro operation, seamlessly complete the BRRR setup process with EPA, and continue handling all the administrative tasks associated with delivering and validating RNG supply under the RFS program.
The Clean Energy team is already taking the appropriate steps to complete submissions to EPA for El Metro's stations.
COMMITTEE R...
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