Comment Log Display
Below is the comment you selected to display.
Comment 133 for Public Comments for LCFS pathway applications (tier2lcfspathways-ws) - 2nd Workshop.
First Name: Stephen
Last Name: Rosenblum
Email Address: pol1@rosenblums.us
Affiliation: Climate Action California
Subject: Concerns about pollution under this permit
Comment:
The air pollution monitoring proposed under this permit is wholly inadequate for the San Joaquin Valley AQMD which is not in compliance with EPA standards for criteria air pollutants. There is only a once in 24 month measurement requirement under condition 19 of the air pollution permit "Source testing to measure NOx, CO, VOC, and ammonia (NH3) emissions from this unit shall be conducted at least once every 24 months. [District Rules 1081, 2201, and 4702]" To have a useful effect, monitoring needs to be continuous. To avoid this problem, methane fuel cells should have been chosen rather than a combustion driven generator. Secondly, there is no requirement to measure methane leakage. If 10% of the methane were to leak this would completely invalidate any benefit to the climate of this activity. Please do not grant this application until these defects are remedied.
Attachment:
Original File Name:
Date and Time Comment Was Submitted: 2023-03-07 19:40:56
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.
