The County of Sonoma operates a large landfill including stationary
combustion with electricity generation. Our only source of fuel is
landfill gas so all our emissions are from biomass. The proposed
changes are for alignment with EPA but also to support cap and
trade. Since all our emissions are from biomass we do not fall
under cap and trade. ARB's proposed changes include going to an
annual verification where EPA does not even require third party
verification. Would ARB consider having an exemption for biomass
CO2 emissions and require only triennial verification?
|