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1. LACSD commends CARB, OEHHA, and CPUC for protecting human health
with respect to the use of biomethane.  We assert that distribution
and use of biomethane via common carrier pipelines is an important
avenue for complying with SB 1383 and the larger goal of
decarbonizing the gas grid.  We noted and appreciate the removal of
benzene as a monitored constituent on account of it being
significantly lower in biomethane compared with natural gas.  We
request CARB to consider requiring the shut-off of biomethane
pipeline injection only when the overall risk of biomethane is
greater than that of common carrier natural gas.
  
2. In reference to the proposed testing by biogas source (page 16
of the October 18 CARB AB 1900 Workshop presentation), please
clarify which set of constituents is required to be monitored when
biomethane is derived from a mixture of feedstocks such as in
co-digestion of wastewater solids with food waste.

3. The existing SoCalGas Rule 45 Section K.5.b requires for testing
to be performed by an independent certified third-party laboratory,
but allows for the interconnector (biomethane producer) to conduct
periodic testing if agreed to by the utility.  We request that
public agencies with laboratories certified by CARB, SCAQMD, or
other certifying agencies be allowed to self-test (i.e., sample
collection and analysis) as long as the laboratory is certified for
the applicable test methods.  Lastly, please clarify if the AB 1900
recommended test methods such as EPA Methods 29 & TO-15 and ASTM
D8230-19 are indeed available for certification, and if so, by
which agency.  Thank you. 

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Date and Time Comment Was Submitted: 2022-11-02 14:57:11