BAC’s Reply Comments on Pipeline Biomethane

The California Public Utilities Commission (CPUC) has reopened its proceeding on pipeline biomethane to reconsider the current standards and incentive programs for pipeline biomethane.  Legislation that BAC sponsored in 2016 required the CPUC to hire the California Council on Science and Technology (CCST) to review pipeline standards for heating value (BTU) and siloxanes.  CCST issued its report earlier this summer recommending a number of changes and the CPUC then asked parties to comment on CCST’s recommendations as well as a number of other issues related to incentives for biomethane.  The CPUC is expected to rule on these issues before the end the year. BAC’s Reply Comments on Pipeline Biomethane focus on several key issues:

  • Need to adopt a biomethane procurement requirement that focuses on instate biomethane production from all organic waste sectors and conversion technologies.
  • Need to increase incentives for pipeline biomethane, including an allocation of the gas utilities’ Cap & Trade revenues and an increase in R&D for biomethane.
  • Support for the California Council on Science and Technology’s recommendations to revise the standards and monitoring requirements for BTU and siloxanes.

CPUC to Consider Revising Pipeline Biogas Standards

California has some of the strictest pipeline biogas requirements in the country, which can add significantly to the costs of pipeline biogas projects.  As a result, the state enacted legislation in 2016 requiring the California Council on Science and Technology (CCST) to review the standards for the heating value (BTU) and siloxanes.  The CCST report recommends that the CPUC consider reducing the BTU requirement to as low as 970.  CCST recommends further study on the siloxanes standard and suggests that monitoring requirements be reduced for biogas sources that are unlikely to have siloxanes (diverted organic waste, dairy, forest and agricultural waste).

Click here to see the CCST study and executive summary.

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.