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Comment 4 for Dairy Subgroup 2 Comment Docket (for digester projects) (dairysubgrp2-ws) - 1st Workshop.
First Name: Joshua
Last Name: Kim
Email Address: joshua.kim@arb.ca.gov
Affiliation:
Subject: RE: Deliverable #2 Regarding "Pipeline Injected Biomethane"
Comment:
[The following comment or question was submitted by email during the June 26, 2017 Subgroup #2 Kickoff Meeting] From: Johannes D. Escudero Affiliation: Coalition for Renewable Natural Gas Responding to Michael Boccadoro’s reply to our comments - Just want to clarify that 1) we agree that Jan 1, 2024 is not a foregone conclusion - but we should also not assume that we will have more time; and 2) RNG projects require an average of $16 million investment per project. IF we have 7 years before SB 1383 takes full effect, and considering it typically takes 7-10 years to amortize the investment capital on an RNG project, we need to do everything we can to encourage and enable the development of as many RNG projects from the dairy sector as soon as possible. The ARB Greet Model/CI score and related LCFS value currently attributed to dairy-manure sourced RNG is necessary in order for dairy manure-derived RNG projects to pencil out.
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Date and Time Comment Was Submitted: 2017-07-12 14:35:59
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