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Comment 12 for Aliso Canyon Mitigation Program Draft (alisompdraft-ws) - 1st Workshop.


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

Subject: ARB methane mitigation plan
Comment:
CR&R Incorporated, one of the largest privately held solid waste
and recycling firms in the U.S. serves some 3 million customers and
more than 50 communities in Southern California. The 50-year old
company will complete the first phase of a four-phase anaerobic
digester (AD) project that will convert source separated organic
waste that would otherwise go to landfill, to renewable natural gas
(RNG) and soil amendments by April of this year. A second phase,
well under construction, will be completed by the fall of 2016.

The project is located in the city of Perris, an economically
disadvantaged community. It will produce one million gallons of
diesel equivalent (DGE) fuel with each phase or 4 million gallons
when fully built out. Each one million gallons of RNG equals about
2500 metric tons of methane. Using the ARB 10-year methane
reduction target in ARB's mitigation plan, two phases of our
project would produce about 50,000 tons of methane mitigation, or
about half of the ten-year mitigation target.

CR&R has privately financed 80% of Phases I and II of the Perris
project with about $8.7 million in grant funds from the California
Energy Commission, CalRecycle and the South Coast Air Quality
Management District and with the support of 10 communities. These
ten communities have supplemented their waste service contracts
with CR&R to enable them to use Phases I and II to manage their
organic wastes and fuel the CR&R trucks serving these communities.

If mitigation funds were made available to CR&R the company would
consider proceeding with Phases III and IV with a completion date
of 2018. The methane production from these two phases, as
previously noted, could achieve half of the methane mitigation
target.


The project would reduce methane from organic waste going to
landfill.

The project location is an economically disadvantaged community.

The project would build on CR&R's existing truck infrastructure,
consisting of several hundred natural gas vehicles and three
natural gas fueling stations, all located in the South Coast.

The project would exploit the use of the new Cummins low NOX .02
gram 8 liter engine that running on RNG, achieves carbon negative
performance. CR&R has been awarded a grant from the South Coast Air
Quality Management District to demonstrate the performance of the
vehicle that goes into commercial production later this year or in
early 2017. 

CR&R has the land use entitlements to all four phases of the AD to
RNG project. The project is thus, "shovel ready."

CR&R will be connected to Southern California Gas Company's gas
grid by the end of 2016. At that time CR&R will become the first
large scale facility of its kind to connect to the grid. It will
then be able to "wheel" its RNG to customers throughout Southern
California.

CR&R is contracting with the City of Los Angeles to help it manage
its residential organic waste. 120 tons per day of organic waste
will be processed at the Perris facility. The city has expressed
interest, subject to proof of project performance, and the
availability of grant funds, to increase green waste deliveries to
the Perris facility.

CR&R's project team of Eisenmann (digester technology from
Germany), Greenlane (gas clean up technology from New Zealand),
Lyles,(an experienced public works contractor)and J.R. Miller,
(architect and engineer for many solid waste facilities nationwide)
brings exceptional capabilities to the development of the project.

The project technology and the development team has been fully
vetted by the City of Los Angeles (Bureau of Sanitation), the
California Energy Commission, Cal Recycle, and the South Coast Air
Quality Management District.

If mitigation funds were used to assist with the development of
Phases III and IV the ARB would have a clear and practical pathway
to achieve its methane mitigation target building on an existing AD
to RNG development platform.


Attachment:

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Date and Time Comment Was Submitted: 2016-03-23 20:40:16



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