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REGARD TO ORDER INSTITUTING RULE MAKING INTO BIOMETHANE ISSUES,PIPELINE OPEN ACCESS, AND RELATED ENFORCEMENT PROVISIONS
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 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.