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Comment 36 for Public Input on Cap-and-Trade Auction Proceeds (investmentplan-ws) - 1st Workshop.


First Name: paul
Last Name: relis
Email Address: paulr@crrmail.com
Affiliation: CR&R Incorporated

Subject: cap-and-trade auction proceeds
Comment:
CR&R Incorporated, a waste services ompany serving more than 45
communities and 2.5 million Southern California customers,
recommends that the ARB use auction fund proceeds to support the
development of an anaerobic digestion (AD) industry to produce
renewable natural gas (RNG)from the organic fraction of the
municipal waste stream.

With $4.52 million in grant assistance from the California Energy
Commission (AB 118 funding) CR&R is investing in an AD facility in
Perris, Riverside County. This privately financed facility will
covert municipal organic waste to RNG. The RNG will power an
estimated 60 or more waste collection trucks and street sweepers
serving municipalities that CR&R contracts with for services.
Assuming the project meets its operational and financial objectives
it will be scaled up. It's estimated that if CR&R is able to
convert 450 of its 700 vehicle fleet about 60,000 metric tons of
GHG emissions reductions will follow. 

CR&R's AD project is scheduled for completion in early 2014.
Project permitting will be completed this fall.

There are about 6 million tons of food and other organic wastes
produced each year in California that are suitable for conversion
to RNG. ARB staff analyses establish that RNG is the cleanest
burning transportation fuel, some six times cleaner than natural
gas. In Germany, RNG is currently being captured from some 7,000 AD
plants in that country. By 2030 Germany estimates that it will
produce 12% of its liquid transportation fuel from AD generated
RNG. 

Given the contribution that AD can make towards realizing AB 32 GHG
reductions, the importance of renewable fuel to California's
transportation sector, and that the RNG fuel source is California
grown and sustainable, carbon trading auction proceeds should
clearly be made available for AD development. Proceeds from the
cap-and-trade program would augment zero carbon fuel incentives
from the Low Carbon Fuel Standard and favorable tax credits for RNG
creating a needed new incentive for the development of a
California-grown AD industry.

From a project criteria perspective CR&R believes that renewable
energy industrial development in California should receive carbon
trading auction proceeds based on its synergistic economic and
environmental benefits to the state. Synergistically AD development
fits the bill. It results in significant GHG reductions, uses local
generated feedstocks to produce the fuel, and produces a soil
amendment that will enrich California's landscape and agricultural
sectors.

An AD industry will produce thousands of high-paying construction
jobs and add a sophisticated, capital intensive new green industry
in California.


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Date and Time Comment Was Submitted: 2012-06-18 15:49:14



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