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Comment 58 for Transportation Symposium to Discuss 50% Petroleum Reduction Goal (transportationsym-ws) - 1st Workshop.


First Name: Evan
Last Name: Edgar
Email Address: evan@edgarinc.org
Affiliation: Ca Compost Coalition

Subject: Support CNG Fleets using RNG to get off Deisel
Comment:
The solid waste and recycling sector heavy-duty fleet is in the
midst of a multi-billion switch from diesel to alternative fuels
(CNG), where up about 80% of the fleet will be CNG by 2020. The
solid waste and recycling industry is co-locating CNG fueling
stations at their facilities that may or may not be publically
accessible. 

To maximize the benefits and achieve the 50 percent petroleum
reduction in the most cost-effective manner, California must invest
in a variety of fuels and technologies across all vehicle types and
transportation sectors, including RNG and not just fund ZEVs. This
includes investments to the CNG fleet that uses a RNG fuel for the
vehicles that collect and haul the organic wastes and run on those
fuels.  With an average incremental costs of $40,000 to purchase a
Class 7 and Class 8 vehicle, the conversion of the diesel fleet to
CNG could cost up to $600 million. CARB should promote the
conversion of the CNG to get off diesel, where the CNG vehicle has
a RNG agreement in place to fuel that CNG vehicle. That could cost
up to $100 million per year for the next 6 years.

RNG does not need to be placed in a pipeline, but can used at the
point of generation to fuel a captive fleet. The AD-to-RNG project
can be designed without a pipeline and the associated leakage as a
community-scale model. This model can collect commercial food waste
feedstocks and achieve a zero waste goal while deploying a
carbon-negative fleet. The co-location of this AD-to-RNG facility
where the fleet is parked is a natural fit by having fueling
stations co-located where biomethane is generated to limit
transmission losses and infrastructure costs. RNG fueling stations
may be time-filled or fast-filled for quick refueling. 

Attachment: www.arb.ca.gov/lists/com-attach/75-transportationsym-ws-BWZdOAFjWVUCZ1c4.pdf

Original File Name: CCC comments on 50% petroleum reduction.pdf

Date and Time Comment Was Submitted: 2015-08-08 15:53:13



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