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Comment 7 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: Work Plan Deliverables
Comment:
[The following comment or question was submitted by email during
the June 26, 2017 Subgroup #2 Kickoff Meeting]

From: Marvin Mears
Affiliation: Environmental Products & Technologies Corporation

To Whom It May Concern

Participated in the web broadcast this morning. The Deliverables
‐ Number 2 is not possible at this time. PG&E and So Cal Gas
have authored two Rules that must be complied with in‐order
to inject RNG into the pipeline. The developer can not comply with
the Rules. Both companies are a monopoly and a 
digester project is a nuisance. RNG as a transportation fuel is
possible with delivery via tube trailers, but not by direct
injection. There is a second problem with injection, the pipelines
have no capacity to transport additional CNG/RNG. There was
discussion about co‐digestion which is easy 
to say but may be hard to do. This could immediately impact in a
negative way the zoning of the dairy and also increase the
traffic to and from the dairy. Last but not least is there is
a good possibility that the dairyman will not allow the digester
effluent to be used as irrigation water.

The focus of this group should be to provide incentives and support
for developers not dairies who do not have the skills or the
ability to raise the funds to build a digester. The dairy’s bank or
accountant do not support this type of activity, which is a big
distraction to their primary business, milking cows and delivering
calves.

Regards

Attachment:

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Date and Time Comment Was Submitted: 2017-07-12 14:35:59



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