Comment Log Display

We propose that all electric generating facility under 95112 be
allowed to aggregate units up to the individual natural gas mains
that enter the facility.  For our facility and many across the
state, the cogeneration facility and standby boiler come off the
same natural gas main.  Allowing electric generating facilities to
aggregate sources up to individual gas mains will provide the most
accurate possible emissions using the utility revenue meters on
each natural gas main. Current regulations and amendments prevent
such aggregation.  Reporting in this manner would allow us minimize
reporting costs and keep ARB reporting consistent with EPA GHG
reporting, which is very important in the economically changed
environment. Allowing continuation of this aggregation method of
reporting will allow ensure future data are consistent with
historical data that has been reported since 2008 to ARB. 

ARB has a desire for supplemental data for specific processes, such
as standby boilers or cogeneration processes.  We have no objection
to providing these subgrouping data, but the meter(s) on these
subgroups will not be as accurate as the utility revenue meter.  As
such we request that emissions for subgrouping be treated as
supplemental data where acceptance of less accurate meters is
allowed. 

As 95112 is written today, it does not strictly allow or prohibit
aggregation of sources.  The aggregation of sources is a subjective
decision by ARB enforced by verifiers.  We request that these
decisions be part of the regulation and public comment period so
that all can be part of the decision.  Furthermore, we ask that ARB
identify clearly what sources are required to meet the fuel
accuracy requirement if we can no longer use our utility revenue
meter.