First Name | William |
---|---|
Last Name | Gibbes |
Email Address | bgibbes@sustainableenergysolutionsllc.com |
Affiliation | Sustainable Energy Solutions LLC |
Subject | Proposed Changes to Section 95852.1.1(b) |
Comment | Sustainable Energy Solutions LLC (SES) is a developer of landfill gas to energy projects. We are currently devloping a High BTU facility to convert landfill gas to Biomethane at a landfill that is not yet subject to NSPS and is currently generating Climate Reserve Tons (CRT's) under the Climate Action Reserve Landfill Project Protocol for voluntary capture and destruction of methane. Our understanding of ARB's intent from participation in public workshops and dialog with ARB staff is that genration and sale of verified CRT's is intended to be allowable and not prevent the Biomethane from being exempt from a compliance obligation. However, the current draft language of Section 95852.1.1(b)is not consistent with this position and needs clarification as to the intent. SES respectfully requests that ARB consider the proposed language as shown on the enclosed file which adds a sentence at the end of section 95852.1.1(b) as follows: Generation and sale of verified Climate Reserve Tons (CRT’s) under the Climate Action Reserve Landfill Project Protocol for voluntary capture of landfill gas and upgrading to Biomethane is allowable and will not prevent a biomass-derived fuel that meets the requirements in this section from being exempt from a compliance obligation. |
Attachment | www.arb.ca.gov/lists/capandtrade10/1277-july_2011_-_arb_first_comment__round_draft_section_95852__-_ses_proposed_changes.docx |
Original File Name | July 2011 - ARB First Comment Round Draft Section 95852 - SES Proposed Changes.docx |
Date and Time Comment Was Submitted | 2011-07-28 09:18:15 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.