Comment Log Display

July 12, 2023
Dr. Cheryl Laskowski
Branch Chief, Low Carbon Fuel Standard Team
California Air Resources Board
Submitted via LCFS Comments Upload Link

RE: CalBio Comments on CARB's Draft Tier 1 Simplified Calculator
for Biomethane from Anaerobic Digestion of Dairy and Swine Manure
released June 20th 2023

Dear Dr. Laskowski:

Thank you for the opportunity to provide comments to the California
Air Resources Board (CARB) on the proposed new Tier 1 Simplified
Calculator for Biomethane from Anaerobic Digestion of Dairy and
Swine Manure released June 20th 2023.
California Bioenergy LLC (CalBio) is a leading developer of dairy
digester projects. Founded in 2006, CalBio works closely with
California dairy farm families, dairy co-ops and cheese producers,
CARB, the California Department of Food and Agriculture (CDFA), the
California Public Utility Commission (CPUC), the California Energy
Commission (CEC), and the U.S. Environmental Protection Agency
(EPA). It develops projects that reduce greenhouse gas (GHG)
emissions, improve local air quality, protect water quality, and
create local jobs. It produces renewable natural gas and generates
electricity, both used as a vehicle fuel to power low emission
trucks, buses, and cars.

CalBio has extensive experience working with the Simplified CI
Calculator for Biomethane from Anaerobic Digestion of Dairy and
Swine Manure (DSM CI Calculator). With over 30 certified Tier 2
pathways, we have developed expertise in both using and
understanding the complexities of this tool. In addition, both our
in-house staff and consultants are skilled greenhouse gas (GHG)
accountants that value incorporating the latest climate science and
emissions factors into the DSM CI Calculator analysis framework and
our project pathways. CalBio is thankful for the opportunity to
share our feedback on the proposed updates and commends CARB on
implementing changes that will make the DSM CI calculator more
streamlined, require less user modifications, and reflect the
latest industry standards for GHG accounting. To that end, please
see our recommendations for improving the DSM CI calculator below:

1. Include controlled/metered venting in the Biogas-to-RNG tab
similar to flaring
CalBio agrees with the revision to include flared biogas to Section
2 of the 'Biogas-to-RNG' tab. However, the DSM CI Calculator is set
up to exclude directly flared biogas from the LCFS pathway system
boundary. From a GHG accounting perspective, CalBio believes flared
emissions at the digester should be treated consistently with how
flared biogas is accounted for at the upgrading facility. To solve
this, CalBio proposes applying the same emissions factor used in
Sections 2.26 and 2.27 to apply to Sections 2.6 and 2.7.

Likewise, we strongly recommend adding controlled/metered venting
to Section 2 of the 'Biogas-to-RNG' tab. It is important to note
that California air quality management districts typically do not
permit flares as the primary mechanism of handling excess biogas
and request that it be vented instead because of air quality issues
in their jurisdictions. Controlled/metered venting is similar to
flaring in that it is biogas produced by the digester and initially
metered at the digester itself but not used to make biomethane
fuel. It likewise becomes a source of emissions that should be
included in the GHG project boundary as part of the lifecycle
production of the fuel. This would be consistent with how the
calculator handles digester leakage and fugitive methane from
upgrading. It is also important to note that venting is an atypical
requirement for out-of-state projects. Therefore, by omitting the
option to include controlled/metered venting as a standard feature
in Section 2 of the DSM CI Calculator would unfairly disadvantage
in-state projects by requiring them to modify the calculator and
thus be ineligible for a Tier 1 pathway.

For the reasons stated above, CalBio believes both
controlled/metered venting and flaring emissions should be included
within the project boundary of the DSM CI Calculator's emissions
analysis. For our certified pathways and applications in the queue,
CalBio modifies the DSM CI Calculator to include controlled/metered
venting that flows to Section L3 of the 'Manure-to-Biogas (LOP
Inputs)' tab and is included in the calculation for project methane
emissions from venting events. Including both flaring and venting
emission sources is in alignment with best practices of lifecycle
GHG analysis as they are project induced.
CalBio has provided CARB with a modified version of the proposed
DSM CI Calculator to demonstrate how these changes could be
implemented.

2. Applicability of New Tier 1 Calculator

CalBio recommends that pathways deemed complete prior to the
effective date of the new LCFS regulation should not be required to
use the new DSM CI Calculator for their first crediting period
under LCFS. These Tier 2 pathway CI calculators have already been
through the validation and projects have been developed, validated,
and certified against a specific standard and public review process
and projects should be given the option, but not the obligation, to
upgrade to the latest version of the calculator. Allowing existing
projects to continue to follow the CI framework in place as they
committed capital and made contractual commitments is sound policy
and consistent with the crediting period concept found in the
current rule and other GHG programs such as Cap & Trade.

3. Account for other process fuels in the Biogas-to-RNG tab

CalBio agrees with the proposed changes to add more process fuel
types in Section 2 of the 'Biogas-to-RNG' tab (e.g., utility
sourced natural gas and diesel for digester energy use and diesel
for biomethane transport). CalBio recommends adding additional fuel
types for biomethane transport such as natural gas, electricity,
and hydrogen. Currently, natural gas is a common fuel type utilized
for biomethane transport in California, thanks to the LCFS, and its
inclusion in the DSM CI Calculator will ensure producers who choose
cleaner fuel types will not have to modify the calculator and
require a Tier 2 submittal. Additionally, it is important to design
the tool to have flexibility in the types of process fuels used in
the DSM CI Calculator for circumstances where different types of
fuel may be used in a single reporting period. For example, an
applicant could start transporting biomethane using diesel fuel and
then transition to natural gas. In this case, it would be practical
to structure the DSM CI Calculator to have different columns
representing each fuel type and its corresponding emission factor
for developers to select from.

4. Develop a separate Tier 1 CI Calculator for DSM to electricity
pathways
CalBio requests that CARB develop a separate Tier 1 CI Calculator
for DSM to electricity pathways to streamline the review process.
Without a stand-alone CI Calculator, all DSM-to-electricity
projects will need to be developed as Tier 2 pathways due to the
required calculator modifications, creating a longer review process
for CARB. CalBio also believes this request is in alignment with
CARB's goals for supporting the electrification of the
transportation sector in California. Project developers want to be
responsive to that goal and build more electric projects to serve
the growing demand for electric vehicles. A separate
DSM-to-electricity CI Calculator will help to ensure there is a
streamlined process for getting electricity projects approved
through the Tier 1 review process. Additional modifications to
improve the DSM-to-electricity CI Calculator are described below.

5. Make explicit that projects can Book & Claim RNG to an offsite
electric generator
CalBio provides the following comments requesting CARB recognize
RNG utilized for offsite electricity generation be allowed as an
eligible pathway type under the existing "Book & Claim" framework.
Under the current regulation, entities can generate LCFS credits by
producing a low-CI transportation fuel such as RNG and injecting it
into a common carrier natural gas pipeline where it is matched to a
CNG fueling station, refinery, or hydrogen facility without having
to physically trace the molecules. Similarly, projects are allowed
to generate electricity at an onsite generator co-located at the
dairy and match electricity production to electric vehicle
charging. CARB recognizes both these transaction types to generate
LCFS results by lowering GHG emissions in each fuel's pathway.
However, the same cannot be said for the use of RNG directed to an
offsite generator to produce electricity. CalBio respectfully
requests CARB update its Book & Claim policy and extend it to apply
when directed biogas RNG is used to generate electricity for
recharging battery-electric vehicles (BEVs) at a location
physically separated from the biogas or hydrogen production. It is
important that these changes be made in the LCFS regulation to
allow maximum flexibility. This will allow biomethane to continue
to expand its contribution to the electric transportation
conversion in-state and to be delivered to high efficiency power
plants that are not always available for small on-site generators.
In this way, the policy change we recommend can help "accelerate
ZEV refueling infrastructure" in California. More renewable
electricity is needed to charge California's growing fleet of
battery electric vehicles (BEVs) and support a more resilient and
reliable grid and CARB's electrification goals.

6. Include other types of electric generator options for
DSM-to-electricity pathways
CalBio requests that CARB include additional generator types and
associated emissions factors within the separate DSM CI Calculator
for electricity projects. CalBio has built the first dairy
biogas-to-fuel cell project, however, the emission factors provided
in the DSM CI Calculator are only those associated with electricity
generation from a conventional stationary reciprocating engine.
CalBio requests there be an option to choose between multiple types
of electricity generating units (e.g., fuel cell, linear generator,
etc.) and use those technology-specific emissions factors. This is
in alignment with CARB's goals of ensuring producers choose more
efficient, cleaner technologies without being pushed into a Tier 2
pathway.

7. Correction to Final Electricity CI for Dairy
Biogas-to-Electricity Pathways
CalBio believes there is flaw in the CARB guidance document 19-06,
Determining Carbon Intensity of Dairy and Swine Manure Biogas to
Electricity Pathways
(https://ww2.arb.ca.gov/sites/default/files/classic/fuels/lcfs/guidance/lcfsguidance_19-06.pdf)
where it directs the user to divide the "Final electricity CI" by
'EF Table'!E89. The value in this cell represents the efficiency of
the electric generator used in the project. This has the seemingly
inadvertent effect of penalizing the project for achieving an
efficiency greater than the 50% benchmark established by CARB. For
example, if a project has a very old, inefficient engine, the CI is
divided by a small number (i.e. 25%) which effectively improves the
CI by making it more negative. An identical project with a
generator efficiency that exceeds the CARB benchmark (i.e. 55%)
means the formula is divided by a higher number, effectively making
the CI score worse by being less negative. The DSM CI calculator is
already structured in a way which caps avoided methane crediting
based on either the lesser of biogas produced and the modeled
"baseline minus project" emission reductions. It does not seem
reasonable to further cap based on efficiency, especially when
CARB's motivation has been to push projects to using more efficient
and cleaner fuel cell technology. This inconsistency should be
corrected in the new calculator such that a project with a higher
efficiency does not get penalized for being more efficient.

8. User Defined Electricity Emission Factors
Every year CARB publishes the prior year's grid electricity factors
(https://ww2.arb.ca.gov/resources/documents/lcfs-pathways-requiring-public-comments).
Applicants should be able to update their Annual Fuel Pathway
Reports to align with these CARB-published values to better reflect
the emissions from electricity utilized at their facilities. This
would require no change to the calculator given it already
accommodates a user-defined electricity mix option, however, CARB
should make it explicit that this is an option developers can make
when submitting or updating their pathways.

9. Incorporate the 5th Assessment Report Global Warming Potentials
(GWP)
CalBio recommends CARB should consider adopting the 100-year GWP
factors from the Intergovernmental Panel on Climate Change (IPCC)
Fifth Assessment Report (AR5). These updated GWPs reflect the
latest climate science on radiative properties and lifetimes of
compounds. The AR5 GWP factors have been adopted by The
Environmental Protection Agency for use in their Inventory of U.S.
Greenhouse Gas Emissions and Sinks.

10. Other small clerical requests
Listed below are few small clerical requests CalBio believes will
enhance the tool.
• Tab: Manure-to-Biogas (LOP Inputs), Section L4.7: Volatile Solids
to Effluent Ponds
o There is a 0.3 degradation factor included in this formula that
is a hard entered value. CalBio recommends adding this value to the
'Reference' Tab with citation to add full transparency to the value
being used in this calculation. This is similar to other values
used throughout the calculator found in the 'Reference' Tab.
• Tab: Biogas-to-RNG, Section 1.10: Average Annual Temperature
(°C)
o Source the average annual temperature from the 'Manure-to-Biogas
(LOP Inputs)' Tab Section L1.1.10 Average Temperature using the
following formula: =AVERAGE('Manure-to-Biogas (LOP
Inputs)'!G9:G32)
• Tab: Biogas-to-RNG, G87; EF Table, F50: CI for compression of
CNG
o With the lower electricity CI at 3-CAMX Mix (314.31 gCO2e/kWh vs.
370.22 gCO2e/kWh), should the CI of CNG compression in CA refueling
stations be reduced to be below 3 gCO2e/MJ (3.5*314.31/370.22 =
2.97)?

We would like to thank CARB for the opportunity to comment and we
look forward to engaging further on the topics above.

Sincerely,
Andrew Craig
Vice President, Greenhouse Gas Programs
California Bioenergy LLC

Original File Name: CalBio Comments 2023 Draft DSM CI Calculator.pdf

Date and Time Comment Was Submitted: 2023-07-12 13:42:49