BAC’s comments on 2014 Draft Integrated Energy Policy Report

The California Energy Commission adopts an Integrated Energy Policy Report (IEPR) every two years and an update every other year.  CEC introduced the draft 2014 Integrated Energy Policy Report in November, 2014.

BAC submitted comments to the CEC supporting biofuels, biogas and issues addressed by the 2014 IEPR.  BAC makes specific recommendations to the CEC on how biofuels can provide immediate and significant GHG reductions, on the need to address pipeline access and cost issues for biogas, on the importance of leveraging funding for clean, low-carbon transportation, among other issues.

Read the Bioenergy Association of California comments here


Read the California Energy Commission 2014 draft IEPR here

Abstract to the IEPR Report:

The 2014 Integrated Energy Policy Report Update provides the results of the California Energy Commission’s assessments of a variety of energy issues currently facing California. These issues include the role of transportation in meeting state climate, air quality, and energy goals; the Alternative and Renewable Fuel and Vehicle Technology Program; current and potential funding mechanisms to advance transportation policy; the status of statewide plug-in electric vehicle infrastructure; challenges and opportunities for electric vehicle infrastructure deployment; measuring success and defining metrics within the Alternative and Renewable Fuel and Vehicle Technology Program; market transformation benefits resulting from Alternative and Renewable Fuel and Vehicle Technology Program investments; the state of hydrogen, zero-emission vehicle, biofuels, and natural gas technologies over the next ten years; transportation linkages with natural gas infrastructure; evaluation of methane emissions from the natural gas system and implications for the transportation system; changing trends in California’s sources of crude oil; the increasing use of crude-by-rail in California; the integration of environmental information in renewable energy planning processes; an update on electricity reliability planning for Southern California energy infrastructure; and an update to the electricity demand forecast.

BAC Releases Groundbreaking Report on Renewable Gas

See BAC’s groundbreaking report on how to decarbonize California’s gas sector.  The report describes the role of natural gas in California, the potential for renewable gas to generate power and fuels, and the need for a Renewable Gas Standard to cut greenhouse gas emissions, create jobs and increase energy security.   Download BAC Report on Renewable Gas Standard.  The report finds that:

  • California imports more than 90 percent of the natural gas it uses, costing the state thousands of jobs and billions of dollars per year.
  • Natural gas causes more than a quarter of the state’s greenhouse gas emissions and is a significant source of air and water pollution.
  • Organic waste alone can produce enough renewable gas to replace ¾ of all the diesel used by motor vehicles in California or enough electricity to power 2 to 3 million homes.
  • Renewable gas produces two to six times as many jobs per megawatt as fossil fuel gas.
  • Replacing just 10 percent of California’s gas supply with renewable gas would reduce greenhouse gas emissions by tens of millions of metric tons per year, while cutting wildfire, air pollution and landfilling.

BAC-CASA Reply Comments on Cost Allocation

R1302008 Reply Comments of BAC and CASA

The Bioenergy Association of California (BAC) and the California Association of Sanitation Agencies (CASA) submit these Joint Reply Comments on cost issues related to pipeline biomethane.  Above all, we urge the Commission to allocate the incremental costs of pipeline biomethane to ratepayers and to allocate a portion of cap and trade revenues to the costs to ensure that this Rulemaking fulfills the purpose of AB 1900, which is to “adopt policies and programs that promote the in-state production and distribution of biomethane.”

BAC-CASA Comments on Cost Allocation

R1302008 BAC-CASA Joint Opening Comments

Pipeline biomethane is probably one of the best and most cost-effective means for the utilities to meet their AB 32 compliance obligations. Pipeline biomethane can also help utility customers that are large emitters to meet their compliance obligations. Increasing pipeline biomethane helps “covered entities” to meet their AB 32 compliance obligations by:

  • Providing a renewable and lower carbon alternative to fossil fuel powered electricity;
  • Providing the lowest carbon transportation fuel available, lower carbon per mile than fuel cell or electric vehicles, to fuel the utilities’ and other large customers’ vehicles.
  • Providing a lower carbon fuel for heating and industrial use; and
  • Reducing emissions of NOx and other pollutants in heavily constrained air districts and environmental justice communities.

CPUC Launches Cost Allocation Phase

Scoping Ruling on AB 1900 – Phase 2

A second phase of this proceeding is being opened by this amended scoping ruling to consider who should bear the costs of meeting the standards and requirements that the Commission adopted in D.14-01-034. In this second phase of this proceeding, the parties will have the
opportunity to file comments and reply comments on who should bear the costs of complying with the Commission-adopted testing, monitoring, reporting, and recordkeeping requirements. This phase will only address these cost issues, and will not be revisiting the standards and requirements that were adopted in D.14-01-034.

Final Pipeline Biomethane Standards (Jan2014)

D. 14-01-034 (Phase 1)

The CPUC issued new standards in January 2014 for biomethane to be injected into common carrier pipelines in California.  The standards address the testing, monitoring and conditioning requirements for 17 constituents of concern.  The standards apply to landfill, dairy and wastewater treatment gas, with other forms of biogas required to meet the standards for wastewater biogas.

Health Protective Standards Report by ARB and OHHA for AB 1900

Click to view the complete AB 1900 Staff Report & Appendices pdf

Recommendations to the California Public Utilities Commission Regarding Health Protective Standards for the Injection of Biomethane into the Common Carrier Pipeline

The staff report of the California Air Resources Board and the Office of Health Hazard Assessment.

AB 1900, authored by Assemblyman Mike Gatto and chaptered into law on September 27, 2012 (Chapter 602, Statutes of 2012), requires the California Public Utilities Commission (CPUC) to develop standards for constituents in biogas to protect human health and pipeline integrity and safety, identify impediments that limit procurement of biomethane in California, and adopt policies and programs that promote the in-state production and distribution of biomethane. To support CPUC’s standards development efforts, the Office of Environmental Health Hazard Assessment (OEHHA) and the Air Resources Board (ARB), in consultation with other State agencies, are to undertake certain actions. Specifically, OEHHA is tasked with compiling a list of constituents of concern found in biogas that could pose a health risk and that are at levels that significantly exceed the concentrations of those constituents found in natural gas. OEHHA is also to determine health protective levels for these constituents. ARB is tasked with developing realistic exposure scenarios and identifying the associated health risk to utility workers and gas end users; determining the concentrations of these constituents in biogas necessary to protect public health; and identifying monitoring, testing, reporting, and recordkeeping requirements necessary to ensure that health protective standards are maintained.

Joint Rebuttal Brief of WM, BAC and CASA

Click to view the complete Joint Rebuttal Brief of WM, BAC, and CASA pdf


Waste Management (WM), the Bioenergy Association of California (BAC) and the California Association of Sanitation Agencies (CASA) respectfully submit this Joint Rebuttal Brief with regard to the Order Instituting Rulemaking into Biomethane Issues, Open Access and Related Enforcement Provisions.  In our Rebuttal, we ask that the Commission issue the following decision:

  • Adopt a heating value for biomethane injected into the pipeline of 950 Btu per standard cubic feet (Btu/scf).
  • With slight modifications for copper and arsenic, adopt for the purpose of protecting health, safety and pipeline integrity only those Constituents of Concern (COC) and Risk Management Levels, including the Trigger, Lower Action and Upper Action levels, and only the testing, monitoring, reporting and recordkeeping requirements for biomethane recommended in the ARB/OEHHA Report[1] with minor modifications agreed to by the parties for retesting and the use of independent laboratories. In the course of adopting the Report’s recommendations, the Commission should affirmatively restrict the Utilities from independently or jointly requiring additional constituents beyond those recommended by the ARB/OEHHA Report and additional testing and monitoring in IOU tariffs or guidelines.
  • Immediately take up issues related to interconnection costs and the adoption of standards required for the injection of biomethane processed from other biogas sources including agricultural waste and other organic wastes.




BAC Comments on Pipeline Biomethane Standards

Click to view the complete BAC Comments on Pipeline Biomethane Standards pdf


Adopting standards that enable pipeline access without undue costs and constraints is very important to BAC’s members. It is also critical to achieve California’s greenhouse gas reduction, renewable energy, clean transportation and other important goals.  California enacted AB 1900 to enable pipeline injection of biomethane because of the many benefits it provides. The Air Resources Board and OEHHA underscored those benefits in their final recommendations for health-based standards, which BAC generally supports. BAC’s comments (attached) address both the proposed public health standards, pipeline integrity and safety standards, and issues related to the utilities’ proposals.