Comment Log Display

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