Comment Log Display

CR&R, a member of the Bioenergy Association of California
(BAC),supports the comments by Julia Levin, Executive Director of
the BAC that will be submitted by this Friday's comment submittal
deadline. We have been a party to preparing those comments.

CR&R is a solid waste/recycling service provider for 50 cities in
Southern California.  We operate a 900 heavy duty-vehicle fleet. We
will complete the construction of a $35 million anaerobic digestion
facility by December of this year that will produce one million
gallons of diesel fuel equivalent (DGE) of biomethane annually.  By
2018 our facility will produce about 4 million DGE gallons per year
of biomethane for use in our waste and recycling collection fleet
based in Perris, CA and for injection into the natural gas grid. It
is expected to be the largest such facility in North America that
converts urban source separated green and food waste, converting it
to biogas and then biomethane.

CR&R offers California a new means of reducing our
reliance on petroleum by 50% that is the goal of the state, along
with making an important contribution to an increased RPS goal and
reductions in GHG emissions.

The BAC has prepared comprehensive comments on the benefits our
industry offers California's efforts to achieve a 50% petroleum
reduction, including providing the lowest carbon transportation of
any kind, near-term reductions in Short-Lived Climate Pollution,
compliance with new organic waste diversion goals, reduced air
pollution impacts on disadvantaged communities suffering from
diesel emissions, reductions in wildfire risk and impacts, and
green job generation.

Given the benefits that facilities like ours offer the state, we
implore you to incentivize fuels such as biomethane to contribute
to the 5 Pillars of California's Climate Change Strategy.  We ask
that you assist in making the injection of biomethane into the
pipeline easier and less costly, provide long-term certainty under
the LCFS and accelerate certification of low-N0x engines and
incentivize their deployment.  And we ask that you allocate Cap and
Trade dollars commensurate with the contribution our industry will
make to supporting the state's Five Pillar platform.

CR&R's investment in its AD facility demonstrates our company's 
commitment to biomethane development in California. CR&R needs the
Air Board to demonstrate its commitment to the development of a
biomethane industry with cap and trade funding and supportive
policies such as long-term LCFS and reducing the costs of
connecting to the gas grid to distribute biomethane.

Together we can make the 50 Percent Petroleum Strategy a practical
reality. 

Sincerely,

Paul Relis
Senior Vice President 
CR&R Incorporated