On Tuesday, January 25th, RCRC and ESJPA submitted joint comments and suggested modifications to a CPUC Proposed Decision ordering PG&E, Southern California Gas Company, San Diego Gas & Electric Company, and Southwest Gas Corporation to procure biomethane derived from eight million tons of organic waste diverted from landfills by 2025.
The Proposed Decision would also require utilities to procure roughly 15% of their natural gas demand from renewable gas from forest management, agricultural waste, and urban wood waste by 2030 and implement pilot projects to convert woody biomass from forest, agricultural, and urban wood waste into biogas.
CPUC staff estimates that the procurement program could increase ratepayer costs 10-13%. In light of that estimate, RCRC and ESJPA urged the CPUC and utilities to do all in their power to minimize any cost increases for customers.
RCRC suggested several modifications to align the proposed decision with the scope of previous discussions and ensure that clean vehicle requirements do not chill interest in the program by biomethane production facilities. While the CPUC seeks to require facilities to prospectively purchase or lease zero emission (ZE) or net zero emission (NZE) vehicles, that is far broader than just the trucks that had been contemplated earlier in the proceeding. Furthermore, there is no offramp for types of trucks/vehicles for which a NZE/ZE option is not commercially available. RCRC also urged the CPUC to clarify that this vehicle requirement only applies to operations at the biomethane production facility itself and not for other operations or vehicles.
Finally, RCRC suggested clarifications and modifications to allow increased onsite electrical generation from landfill gas collection systems from participating facilities, if non-combustion systems are not feasible, increased on-site energy generation will produce fewer emissions than flaring, and that emissions from increased on-site energy generation will be mitigated or reduced.
For more information, please contact RCRC Policy Advocate, John Kennedy.