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Dear Mr. Whitney,
Office of the
INDIAN RIVER COUNTY
ADMINISTRATOR
John A. Titkanich, Jr., County Administrator
Michael C. Zito, Deputy County Administrator
Nancy Bunt, Assistant County Administrator
Thank you for your correspondence dated May 31, 2026, issued on behalf of Nopetro Eco
District LLC (Nopetro) and your engineering firm, Tetra Tech, providing formal notice of intent
to implement a Commercial and Environmental Improvement (CEI) project at the Indian River
County Landfill. Your proposal specifically outlines the temporary installation of horizontal gas
collection wells within Segment 3, Cells 2 and 3, to address recent declines in available landfill
gas volumes and enhance operational performance at the Renewable Natural Gas facility.
Pursuant to the Staff Recommendation approved by the Indian River County Board of County
Commissioners, I am pleased to issue this formal letter of approval for the proposed CEI project.
This authorization allows Nopetro to proceed with project implementation in accordance with
Section 3.3C of the Third Amendment to the Landfill Gas Agreement originally dated July 16,
2019, as amended through the Fourth Amendment heard by the Board on January 23, 2024.
This approval is granted subject to full compliance with all prevailing regulatory framework
constraints. The County acknowledges that this infrastructure is being deployed as a temporary
measure under consultation with the Florida Department of Environmental Protection (FDEP)
and, as presented, is anticipated to require no formal permit modifications. Nopetro remains fully
responsible for maintaining regulatory conformity throughout the operational lifespan of these
improvements.
Furthermore, consistent with the financial terms set forth in your notice, the County confirms
that Nopetro will fully finance this CEI project. There are no current, recurring, or future
budgetary impacts or financial obligations imposed upon the Solid Waste Disposal District
(SWDD) or Indian River County. Nopetro shall cover all costs associated with construction,
maintenance, and eventual decommissioning of the temporary network.
To ensure continuous, safe, and compliant operations at the facility, Nopetro is required to
coordinate all near-term field activities, construction sequencing, and site access protocols
directly with SWDD staff and Republic Services. This collaborative oversight is essential to
guarantee that the installation does not conflict with active landfill management or ongoing daily
operations.
We value Nopetro's continued investment in the County's infrastructure, governance objectives,
and sustainable energy frameworks, and we look forward to the successful execution of this
project to enhance gas quality and volume recovery.
Sincerely,
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John Tit inch, Jr.
County Administrator
NOPETRO
ENERGY
May 29, 2026
Mr. Himanshu Mehta, P.E.
Managing Director
Indian River County — Solid Waste Disposal District
1325 74th Avenue SW, Vero Beach, FL 32968
Subject: Indian River County Solid Waste Disposal District
Notification of Interim GCCS Well Construction within Cell 3
Dear Mr. Mehta,
'NW W NOPf TRO COM
As you are aware, the Landfill Gas (LFG) quantity being sent from the Indian River County
(IRC) Landfill to Nopetro is well below SCS Engineer's LFG Recovery Projection Study (SCS Landgem)
used to support the Renewable Natural Gas (RNG) Plant Design Basis. To address and remedy this
situation, it is necessary to install conventional horizontal wells in Segment 3, Cells 2 and 3 — the new,
active area of the landfill (the "Project"). Nopetro is committed to safely performing this work beginning
as early as late June. Below find detailed information to support this effort.
Throughout 2023, and prior to the design of the RNG Plant, IRC's inlet flow meter indicated LFG
generation volumes around 1,100 standard cubic feet per minute (scfm) ultimately peaking at 1,248 scfm
in March 2024. These peak volumes were measured at the time IRC installed the Slide Slope Collectors
within Segment 2, and they were consistent with the SCS Landgem projections. However, since that
time, LFG quantities available for RNG production have steadily declined, dropping to 600 SCFM in
May 2026.
Based on the SCS Landgem and supported by the 2023 IRC LFG generation meter data,
Nopetro's RNG Plant was designed to receive a minimum of 1,000 scfm of LFG and maximum of 2,000
scfm. Construction of the RNG Plant began in August 2024, and at commissioning in July 2025, LFG
available for plant startup averaged —688 scfm. Despite the lower volume, to allow plant start-up,
Nopetro was able to install a recycling line within the plant process to allow for operations to commence.
Operation today continues with the lower LFG volume and with the recycling line, but this has resulted in
lost methane recovery efficiency and reduced income generation.
One of the root causes of the low LFG volume is due to the lack of Gas Collection and Control
System (GCCS) infrastructure in Segment 3, Cells 2 and 3. Indeed, in 2025, IRC began construction of
Segment 3, Cell 3 to prepare it for new filling of municipal solid waste (MSW). However, currently there
is no GCCS infrastructure in this Cell and consequently the methane/gas being generated is escaping into
the atmosphere. To support gas recovery from Cells 2 and 3, Nopetro requests approval from IRC to
allow construction of a horizontal well network. This is a common interim gas collection method for new
landfill cells to allow capture during the early filling phase and prior to the installation of vertical gas
extraction wells. This is an industry standard for GCCS expansion. First, upon new cell expansion,
horizontal wells are installed, and then once waste reaches a certain height, vertical wells are installed.
US Locations
MX Locations
HQ
Miami
Guadalajara
150 SE 2"'Avenue PH1 Vero Beach
Mexico City
Miami. Florida. 33131 Orlando
T. 305.441.9059 Tallahassee
F. 305.441.9085 St Augutine
NOPETRO
ENERGY
WWW NODETRO COM
To assist Nopetro and IRC in this effort, we engaged Tetra Tech, a leading U.S. landfill engineering
services company, to provide expert input and a recommend horizontal well design. Tetra Tech completed
its design in late May and determined that these wells can be installed as an Interim Gas Collection
Device per the Florida Department of Environmental Protection (FDEP) statutes. Accordingly, attached
find a draft Notice regarding the horizontal well installation, which with your approval, Nopetro will
request that Tetra Tech forward to the FDEP on behalf of IRC SWDD.
Upon approval by IRC's Board of County Commissioners, and in collaboration with both the IRC
Solid Waste Department and Republic Services, Nopetro is prepared to pay for and install these
horizontal wells. Moreover, the horizontal wells will be installed in close coordination with Republic
Services to ensure that there is no interruption to daily landfill operations. This project will be completed
by Nopetro in accordance with the terms and conditions of the Landfill Gas Agreement dated July 16,
2019, and as amended thereto.
Lastly, it is imperative to note that due to Cell 3's current fill rate, any delay in mobilization to
complete the field effort will have a significant negative impact on the ability to install the horizontal
wells necessary to capture LFG until 2029 when projected waste elevation would accommodate vertical
well installation. As such, time is of the essence to begin the project.
We respectfully request approval so that the Project can proceed, and the schedule be finalized for
construction to begin late June 2026.
Sincerely,
7ee�_WUAZ6
Mike Whitney
SVP Operations
Nopetro
Cc: Sean Lieski
Jorge Herrera
Attachments: draft Notification letter to FDEP
Horizontal Well Site Plan
MX Locations
Guadalajara
Mexico City
US Locations
HQ
Miami
e
150 SE 2—Avenue - PHI
Vero Beach
Miami. Florida.
Orlando
T. 305.441.9059
Tallahassee
F. 305.441.9085
St Augutine