First Name | Patrick |
---|---|
Last Name | Serfass |
Email Address | pserfass@ttcorp.com |
Affiliation | American Biogas Council |
Subject | 6 Suggested Changes from the American Biogas Council |
Comment | The American Biogas Council (ABC) represents 120 companies dedicated to the development of anaerobic digestion technologies and the expanded use of biogas. While many of the parameters in ARB’s cap and trade regulations will generate the development and use of this key resource, we would appreciate ARB’s consideration of the following recommendations to simplify its regulations and further bolster the use of biogas: • Change the Contracting Deadline for Purchase of Biomass-Derived Fuel to January 1, 2013 from January 1, 2012 • Simplify the grandfathering concept for biomass derived fuel that is purchased before the start of the program • Ensure biogas projects continue to receive offset credits for the destruction of methane • Include efficiency increases in the definition for increased capacity • Remove the requirement that a contract must remain in effect with the same California operator • Remove the requirement in MMR section 95131(i) for mid-year or intermediate verifications for biomass derived fuels if there are volume increases or upstream title changes |
Attachment | www.arb.ca.gov/lists/capandtrade10/1399-abc_comments_to_arb_-_10_august_2011.pdf |
Original File Name | ABC Comments to ARB - 10 August 2011.pdf |
Date and Time Comment Was Submitted | 2011-08-11 08:28:26 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.