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Environmental Power applauds the California Air Resources Board
(ARB) for recognizing the benefits of anaerobic digestion and
biogas in the Climate Change Draft Scoping Plan (“Draft Plan”). 
Methane is a potent greenhouse gas (GHG) and methane emissions
from agricultural livestock and organic waste contribute to global
climate change.  By creating incentives for changes in manure
management practices, wastewater treatment processes, increased
source separation of organics from methane-producing activities,
and encouraging the capture and beneficial use of biogas as a
renewable resource, ARB can achieve greenhouse gas emission
reductions.

We agree that biogas produced from livestock-based anaerobic
digesters are already an important contributor to the State’s
efforts to produce 12 percent of California’s retail electric load
from renewable resources.  Efforts to increase the target RPS to 33
percent will require an even greater contribution from this
resource.  However, anaerobic digestion is only one of a broad
range of options of exists to encourage reductions from this
sector and we support the ARBs conclusion that providing economic
incentives such as marketable emission reduction credits,
favorable utility contracts, or renewable energy incentives will
stimulate the implementation of various captured gas methods and
methane reduction and that efforts to mandate the use of digesters
would not be an appropriate path.  The initiative undertaken by ARB
and the California Climate Action Registry on developing a
livestock digester protocol already assures that digester projects
that do get constructed can quantify their emission reductions in a
verifiable manner that ensures the integrity of any offsets that
might be used for compliance obligations in other sectors. 

We would like to draw ARB’s attention to the potential for
additional methane capture and beneficial use in wastewater
treatment systems.  Projects undertaken to reduce methane
emissions from these operations should also be provided the
opportunity to create a tradeable offset which can be used by
other sectors to meet compliance obligations.

Anaerobic digestion should also be incorporated into the recycling
and waste initiatives in the Draft Plan.  The technology we employ
can also use food industry and related agricultural product waste
streams that are separated from other municipal waste streams to
produce additional biogas.  This co-digestion process can reduce
GHG emissions compared to current practices when there are
sufficient incentives.

One specific issue that needs further attention in the Draft Plan
is the manner in which carbon fees are assessed.  As laid out in
the Draft Plan, the fees would be levied on natural gas flowing
through any of the state’s seven interstate natural gas pipelines.
 As some of the natural gas that will flow through those systems
will be biogas conditioned to pipeline quality standards and will
be GHG-free, we suggest that a mechanism by which ARB could track
“green” gas (renewable gas) so that renewables are not assessed
the carbon fee be created.  

Environmental Power is pleased that ARB has included biogas as a
solution in the Draft Plan.  Biogas deserves to be part of the
comprehensive approach to climate change, and will serve as a
valuable resource in both GHG emission reduction and renewable
energy generation.  We look forward to working with the State of
California in realizing its goals of reducing overall carbon
emissions, improving the environment, reducing dependence on oil,
diversifying energy sources, saving energy, and enhancing public
health while creating new jobs and enhancing growth in
California’s economy.

Mark Hall
Senior Vice President
Environmental Power Corporation

Original File Name:

Date and Time Comment Was Submitted: 2008-07-30 14:09:12