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Attachment 2 <br /> Rincon Consultants, Inc. <br /> 1 <br /> 449 15th Street, Suite 303 <br /> Oakland, California 94612 <br /> 510 834 4455 OFFICE <br /> info@rinconconsultants.com <br /> www.rinconconsultants.com <br /> Date: March 15th, 2023 <br /> Project No: 23-14064 <br /> Becky Hopkins, Assistant to the City Manager <br /> City of Pleasanton <br /> 123 Main Street <br /> Pleasanton, California 94566 <br /> Via email: _BHopkins@cityofpleasantonca.gov <br /> Subject: City of Pleasanton CAP 2.0, Greenhouse Gas Analysis of Natural Gas Replacement with <br /> Renewable Natural Gas, Pleasanton, CA 94566 <br /> Dear Ms. Hopkins: <br /> The City of Pleasanton is proposing to purchase Senate Bill (SB) 1383 compliant renewable natural gas <br /> (RNG)to replace the use of fossil natural gas in municipal owned buildings. This effort is primarily for the <br /> purposes of meeting the procurement target for organic waste set for the City set by SB 1383.The <br /> proposed RNG is a product of wastewater and diverted food waste.The project developer is able to <br /> comply with the record keeping requirements of SB 1383 for gas produced at a publicly owned <br /> treatment works(POTWs) and demonstrate that the produced RNG meets the eligibility requirements <br /> for meeting the procurement target as outlined in 14 CCR Section 18993.1 (h). The project generating <br /> the RNG is connected to a distribution system in Southern California and therefore would be procured <br /> by the City through a contract. <br /> While the purpose of obtaining RNG for municipal owned buildings is to meet the procurement target <br /> for the City set by SB 1383, the replacement of fossil natural gas with RNG also has greenhouse gas <br /> (GHG) emission reduction benefits.The following sections of this memorandum describe legislation <br /> demonstrating how the environmental attributes of RNG may be applied to GHG emission estimates, <br /> summarize the GHG emission reductions associated with RNG procurement by the City, and provide a <br /> cost-benefit analysis associate with the GHG savings. <br /> RNG Environmental Attributes <br /> Under California Air Resources Boards (CARB's) Low Carbon Fuel Standard (LCFS) program,the one-to- <br /> one replacement of fossil natural gas with pipeline-injected RNG is based on book-and-claim accounting. <br /> Book-and-claim accounting refers to the chain-of custody model in which decoupled environmental <br /> attributes(in this case GHG emissions reductions) are used to represent ownership and transfer of the <br /> fuel without regard to physical traceability.To ensure that environmental attributes are not double <br /> counted, chain-of-custody evidence must demonstrate that the environmental attributes linked to the <br /> injected RNG are tied with corresponding quantities of natural gas withdrawn.) This can be <br /> demonstrated through contracts between the producer and the entity withdrawing the natural gas. For <br /> 1 Low Carbon Fuel Standard (LCFS) Guidance 19-OS <br /> E n v i r o n m e n t a l S c i e n t i s t s r E n g i n e e r s <br />