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Comment 59 for Public Comments for LCFS pathway applications (tier2lcfspathways-ws) - 2nd Workshop.
First Name: Doug
Last Name: Verboon
Email Address: doug.verboon@co.kings.ca.us
Affiliation:
Subject: B104 Application Question
Comment:
My name is Doug Verboon, and I am currently the Chairman of the Board of Supervisors in Kings County. I am writing in response to applications B104, B105, and B106, published on your website for public comment. According to public data, the dairy digesters affiliated with these three applications are currently selling their power output to the local utilities under the Bioenergy Market Adjusting Tariff (BioMAT). The CPUC-approved language of the BioMAT contract requires generators to turn over to the purchasing utility all Renewable Energy Credits (RECs, aka Green Tags) associated with the power generated. However, the LCFS program requires any RECs used for vehicle fueling need to be retired by the pathway holder, to prevent double counting. Given these two conflicting requirements for RECs, how has CARB determined that no double counting is occurring? I represent Kings County, which has multiple BioMAT generators and would like to know what public, transparent process might exist (if any) that would enable my constituents to participate in both programs.
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Date and Time Comment Was Submitted: 2020-11-25 14:22:19
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