First Name | Bill |
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Last Name | Buchan |
Email Address | buchan@mktpotential.com |
Affiliation | Graphic Packaging Int, Inc. |
Subject | Aggregation of Electric Generating Units |
Comment | 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, the 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. Current regulations and amendments prevent such aggregation. Reporting in this manner would allow us minimize reporting costs and keep ARB reporting consistent with EPA GHG reporting, which is very important in the economically changed environment. Allowing continuation of this aggregation 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 subgrouping data, 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. 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. |
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Original File Name | |
Date and Time Comment Was Submitted | 2012-09-18 08:19:13 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.