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, our 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.
Reporting in this manner would also keep ARB reporting consistent
with EPA GHG reporting, allow us to minimize GHG reporting costs.
Allowing continuation of this 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 data as subgroups, 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.  Clarification is needed.  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.