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Comment 11 for Dairy Subgroup 2 Comment Docket (for digester projects) (dairysubgrp2-ws) - 1st Workshop.
First Name: Joshua
Last Name: Kim
Email Address: joshua.kim@arb.ca.gov
Affiliation:
Subject: Comment on CI Scores and the Draft Dairy Crediting Guidance Document
Comment:
[The following is a comment/question submitted to CARB related to dairy topics under consideration and discussion by the agency and the dairy/livestock subgroup #2.] From: David DeVooght Affiliation: Amerex Energy Comment: We are working with a number of companies that are planning on utilizing RNG from dairy digester projects that have already registered as CCO projects. These facilities will be converting from electricity to pipeline quality RNG, and ultimately sending this to California to generate LCFS credits. Based on the CARB released regulatory guidance for digesters, projects that generate LCFS credits from avoided methane will be required to follow the CARB Livestock Protocol. The CARB Protocol allows for a 10 year crediting period for CCOs. My question is, if an existing CCO producing livestock digester registers with the LCFS and is awarded a (approx.) -200 CI score that includes avoided methane emissions, does the 10 year crediting period for the CI score apply? For example, if there is a project that registered and started producing CCOs in 2015 and begins sending RNG to California generating LCFS credits in 2020, does this project only receive LCFS methane avoidance credits for an additional 5 years (2020-2025)?
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Date and Time Comment Was Submitted: 2018-03-26 11:04:04
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