Comment Log Display

Sustainable Energy Solutions LLC (SES) is a developer of landfill
gas to energy projects. We are currently devloping a High BTU
facility to convert landfill gas to Biomethane at a landfill that
is not yet subject to NSPS and is currently generating Climate
Reserve Tons (CRT's) under the Climate Action Reserve Landfill
Project Protocol for voluntary capture and destruction of methane.
Our understanding of ARB's intent from participation in public
workshops and dialog with ARB staff is that genration and sale of
verified CRT's is intended to be allowable and not prevent the
Biomethane from being exempt from a compliance obligation. 
However, the current draft language of Section 95852.1.1(b)is not
consistent with this position and needs clarification as to the
intent. SES respectfully requests that ARB consider the proposed
language as shown on the enclosed file which adds a sentence at the
end of section 95852.1.1(b) as follows:
Generation and sale of verified Climate Reserve Tons (CRT’s) under
the Climate Action Reserve Landfill Project Protocol for voluntary
capture of landfill gas and upgrading to Biomethane is allowable
and will not prevent a biomass-derived fuel that meets the
requirements in this section from being exempt from a compliance
obligation.