BILL ANALYSIS                                                                                                                                                                                                    Ó



          SENATE COMMITTEE ON ENVIRONMENTAL QUALITY
                              Senator Wieckowski, Chair
                                2015 - 2016  Regular 
           
          Bill No:            SB 1043
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          |Author:    |Allen                                                |
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          |Version:   |4/7/2016               |Hearing      |4/20/2016       |
          |           |                       |Date:        |                |
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          |Urgency:   |No                     |Fiscal:      |Yes             |
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          |Consultant:|Rebecca Newhouse                                     |
          |           |                                                     |
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          SUBJECT:  Renewable gas:  biogas and biomethane

            ANALYSIS:
          
          Existing law:  
          
          1)Under the California Global Warming Solutions Act of 2006, also  
            known as 
            AB 32, requires the California Air Resources Board (ARB) to  
            determine the 1990 statewide greenhouse gas (GHG) emissions  
            level and approve a statewide GHG emissions limit that is  
            equivalent to that level, to be achieved by 2020, and to adopt  
            GHG emissions reductions measures by regulation.  ARB is  
            authorized to include the use of market-based mechanisms to  
            comply with these regulations.  (Health and Safety Code §38500  
            et seq.) 

          2)Under the Renewable Portfolio Standard (RPS) requires  
            investor-owned utilities (IOUs), publicly owned utilities  
            (POUs) and certain other retail sellers of electricity to  
            achieve 50% of their energy sales from an eligible renewable  
            electrical generation facility by December 31, 2030, and  
            establishes portfolio requirements and a timeline for  
            procurement quantities of three product categories.  (Public  
            Utilities Code §399.11 et seq.)

          3)Provides that electricity produced by certain renewable energy  
            resources, including natural gas produced from biomass,  
            digester gas or landfill gas, as potentially eligible for  
            credit under the RPS (PUC §399.12, Public Resources Code  







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            §25741)

          4)Requires the Office of Environmental Health Hazard Assessment  
            (OEHHA), in consultation with ARB, and other specified  
            agencies, to compile a list of constituents of concern that  
            could pose risks to human health and that are found in biogas  
            at concentrations that significantly exceed the concentrations  
            of those constituents in natural gas and requires OEHHA to  
            determine the health protective levels for that list, and  
            requires ARB to identify realistic exposure scenarios and the  
            health risks associated with those scenarios to determine  
            acceptable threshold concentrations of those constituents.  
            (HSC §25421)

          5)Requires the California Public Utilities Commission (CPUC) to  
            adopt standards for biomethane to be injected into a common  
            carrier pipeline that specify constituent concentrations that  
            are reasonably necessary to ensure the protection of human  
            health, giving due deference to the findings by OEHHA, ARB,  
            and other specified agencies.  (HSC §25421)

          6)Requires California Energy Resources Development and  
            Conservation Commission (CEC) to hold public hearings to  
            identify impediments that limit procurement of biomethane in  
            California, including, but not limited to, impediments to  
            interconnection, and requires CEC to offer solutions to those  
            impediments as part of the integrated energy policy report.   
            (PRC §25326)

          7)Defines "biogas" as gas that is produced from the anaerobic  
            decomposition of organic material and "biomethane" as biogas  
            that meets the standards adopted by CPUC for injection into a  
            common carrier pipeline.  (HSC §25420)

          8)Requires PUC to adopt policies and programs that promote the  
            in-state production and distribution of biomethane.  (PUC  
            §399.24 )

          9)Defines "biomass conversion" as the production of heat, fuels,  
            or electricity by the controlled combustion or use of  
            non-combustion thermal conversion technologies on specified  
            organic materials, including specified agricultural crop  
            residues, bark, wood chips, and other green wastes. 









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          10)Specifies that "biomass conversion" does not include  
            controlled combustion of sewage sludge, among other materials.  


          This bill:  

          1) Directs ARB to consider and adopt policies, as appropriate,  
             to significantly increase the sustainable production and use  
             of "renewable gas," and requires ARB to do the following:

             a)    Ensure any policy is coordinated and consistent with  
                state policies to promote renewable fuels and renewable  
                resources, reduce life-cycle GHG and short-lived climate  
                pollutant emissions, increase carbon sequestration, divert  
                organic waste from landfills, reduce air and water  
                pollution, reduce wildfires, promote resilient and  
                sustainable forests, and protect the environmental quality  
                of natural and working lands.
                 
             b)    Ensure in consultation with the Department of Resources  
                Recovery and Recycling (CalRecycle) that any adopted  
                policy recognizes declining landfill gas in future years.

             c)    Ensure that the production and use of renewable gas  
                provides direct benefits through helping the state meet  
                landfill diversion goals, or avoiding or reducing criteria  
                pollutants, short-lived climate pollutant and GHG  
                emissions in the state, emissions that adversely affect  
                the waters of the state, and nuisances associated with the  
                emission of odors.

             d)    Identify barriers to the rapid development and use of  
                renewable gas and make specific recommendations to remove  
                those barriers and identify potential sources of funding  
                to provide incentives for renewable gas production and  
                use. 

             e)    Coordinate with CPUC, CEC, POUs, CalRecycle and the  
                Department of Forestry and Fire Protection.

          2) Requires ARB to develop and adopt a life cycle GHG and  
             short-lived climate pollutant accounting method associated  
             with biogas produced from forest biomass, as specified.









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          3) Modifies the definition of "biogas" and "biomethane" as  
             currently used in statute concerning biogas injection into  
             common carrier pipelines by defining "biogas" as a gas  
             produced from organic waste through anaerobic digestion, or  
             conversion technologies, as specified, and "biomethane" as  
             methane derived from biogas. 

          4) Defines "biogas," for purposes of the work required of ARB by  
             this bill, to have the same meaning  as above, except that it  
             does not include gas produced from forest biomass unless it  
             is produced from forest waste remaining after all other  
             reasonable forest products have been produced and it meets at  
             least one of several specified conditions.

          5) Defines "renewable gas" to mean biogas or synthetic gas  
             generated by an eligible renewable energy resource meeting  
             the requirements of the California Renewables Portfolio  
             Standard Program, but not including organic waste.

          6) Amends the definition of "biomass conversion" to include  
             byproducts or residue from composting as eligible organic  
             feedstocks for combustion or non-combustion conversion  
             technologies.  

          7) Strikes "sewage sludge" from the materials prohibited from  
             being feedstocks under the definition of biomass conversion. 

          8) Specifies that the requirements for ARB to consider and adopt  
             policies, as appropriate, to increase the production and use  
             of renewable gas is not intended to affect health and safety  
             standards adopted by CPUC prior to January 1, 2016 for  
             biomethane that is to be injected into the pipeline. 

            Background
          
          1) Short-lived Climate Pollutants. Greenhouse gases or climate  
             pollutants, such as CO2, work to warm the earth by trapping  
             solar radiation in the earth's atmosphere. Depending on the  
             molecule, these pollutants can vary greatly in their ability  
             to trap heat and the length of time they remain in the  
             atmosphere.  CO2 remains in the atmosphere for centuries,  
             which makes it the most critical greenhouse gas to reduce in  
             order to limit long-term climate change.  However, climate  
             pollutants including methane, tropospheric ozone,  








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             hydrofluorocarbons (HFCs), and soot (black carbon), are  
             relatively short-lived (anywhere from a few days to a few  
             decades), but when measured in terms of how they heat the  
             atmosphere (known as global warming potential or GWP), can be  
             tens, hundreds, or even thousands of times greater than that  
             of CO2.  These climate forcers are termed short-lived climate  
             pollutants (SLCPs).

             Because SLCPs remain in the atmosphere for a relatively short  
             period of time, but have a much higher global warming  
             potential than CO2, efforts aimed at reducing their emissions  
             in the near term would result in more immediate climate, air  
             quality, and public health benefits, than a strategy focused  
             solely on CO2. According to ARB's SLCP draft strategy, "while  
             the climate impacts of CO2 reductions take decades or more to  
             materialize, cutting emissions of SLCPs can immediately slow  
             global warming and reduce the impacts of climate change."  
             Recent research estimates that SCLPs are responsible for  
             about 40% of global warming to date and that actions to  
             reduce SLCP emissions could cut the amount of warming that  
             would occur over the next few decades by half. 

             According to ARB's 2015 updated Scoping Plan, methane is one  
             of the three short-lived climate pollutants with the greatest  
             implications for California. 

             Methane (CH4) is the principal component of natural gas and  
             is also produced biologically under anaerobic conditions in  
             ruminants, landfills, and waste handling.  Atmospheric  
             methane concentrations have been increasing as a result of  
             human activities related to agriculture, fossil fuel  
             extraction and distribution, and waste generation and  
             processing. A 2014 Stanford University study found that  
             methane emissions may be 50% higher than official estimates  
             from the US EPA.  In 2010, ARB approved a regulatory measure  
             as an AB 32 (Nuñez, Pavley, Chapter 488, Statutes of 2006)  
             discrete early action measure that requires installation of  
             landfill gas collection and control systems.  ARB has also  
             released draft regulations to reduce fugitive methane from  
             the oil and gas sector.  Methane is 84 times more powerful as  
             a global warming pollutant than CO2 on a 20-year time scale.

          2) Biogas, methane, and biomethane.  Through a series of steps  
             involving the bacterial breakdown of organics, carbon-based  








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             material can be converted to methane in oxygen-deprived  
             conditions.  This process occurs naturally, and is often  
             uncontrolled in landfills and dairies, contributing to  
             significant GHG emissions.  However, capturing and utilizing  
             the gas is facilitated through the use of anaerobic  
             digesters, which operate with various temperatures, pH and  
             bacteria types.  The digestion process dramatically speeds up  
             the natural decomposition process for organic wastes to  
             produce primarily methane, significant quantities of carbon  
             dioxide, and trace amounts of other gasses including  
             hydrogen, carbon monoxide, nitrogen, oxygen, and hydrogen  
             sulfide, which, all together, is termed "biogas."  The biogas  
             can be processed further to produce high purity, or  
             "pipeline" quality methane, and is termed biomethane to  
             differentiate it from fossil fuel natural gas.  In addition  
             to production at landfills and dairies, biomethane can be  
             generated from digestion processes at wastewater treatment  
             plants.  Biomethane is also termed renewable natural gas, or  
             RNG.

          3) Biomethane fuel supply, markets, and barriers to use.   
             Because of the potential climate, waste reduction, and energy  
             benefits of biomethane, a number of bills and programs have  
             worked to increase the supply, expand the biomethane market,  
             and overcome barriers for its use.  Various incentive  
             programs, funded through cap-and-trade auction revenue, and  
             by vehicle registration surcharges, provide grants and loans  
             for the production of renewable and alternative fuels,  
             including biomethane. 

             The state has also implemented several programs to create  
             markets for low-carbon fuels, in furtherance of meeting GHG  
             emission reduction goals.  The Low-Carbon Fuel Standard  
             (LCFS), established pursuant to authority under AB 32,  
             requires a 10% reduction in the carbon intensity for  
             transportation fuels used in the state by 2020.  The state  
             also has procurement requirements for "very-low carbon  
             fuels," established through AB 692 (Quirk, Chapter 588,  
             Statutes of 2015).  Biomethane is also considered a renewable  
             resource under the Renewable Portfolio Standard, which was  
             recently amended by SB 350 (de León and Leno, Chapter 547,  
             Statutes of 2015) to require 50% of total retail electricity  
             sales to be from renewable energy resources by 2030.   
             Additionally, the cap-and-trade regulation allows covered  








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             entities to purchase up to 8% of their compliance obligation  
             as offsets.  To date, ARB has adopted offset protocols for  
             four project types including dairy digesters to capture  
             fugitive methane emissions.

             Overcoming barriers.  Due to concern over toxic constituents  
             in landfill biogas, California adopted strict requirements in  
             1988 regarding the allowable levels of vinyl chloride and the  
             required testing protocols for the legal sale, supply or  
             transport of landfill gas to a gas corporation in the state.   
             In an effort to encourage the production and use of  
             biomethane in California, including methane produced from  
             landfill biogas, the Legislature passed AB 1900 (Gatto,  
             Chapter 602, Statutes of 2012), which required the CPUC to  
             adopt health and safety standards for biomethane pipeline  
             injection based on recommendations from OEHHA and ARB.  AB  
             1900 also requires CPUC to "adopt policies and programs that  
             promote the in-state production and distribution of  
             biomethane."  On January 16, 2014, CPUC adopted health and  
             safety standards for pipeline injected biomethane. 

             In 2015, CPUC found that gas producers should bear all costs  
             relating to the processing and pipeline injection of  
             biomethane.  As part of that decision, the CPUC adopted a $40  
             million ratepayer-funded program to offset a portion of the  
             costs to gas producers of connecting to utility pipelines.   
             Program funding will pay up to 50% of a biomethane project's  
             interconnection cost, up to $1.5 million per project. 

             AB 1900 also required CEC to hold public hearings to identify  
             impediments that limit procurement of biomethane in  
             California and offer solutions as part of the Integrated  
             Energy Policy Report (IEPR).

            Comments
          
          1) Purpose of Bill.  According to the author, "California is a  
             leader in efforts to combat climate change - one of the most  
             daunting challenges facing humanity.  Currently, California's  
             gas sector causes one-quarter of the state's greenhouse gas  
             emissions, and is a major contributor to global warming.  

             "California uses more than 2 trillion cubic feet of natural  
             gas per year and that amount is going up.  Natural gas is  








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             used to generate more than half of the state's electricity,  
             the majority of its home heating and hot water, and a growing  
             share of transportation fuels.  Although cleaner and cheaper  
             than other fossil fuels, natural gas is a major source of  
             greenhouse gas emissions and air and water pollution.  In  
             addition, California imports 91% of its gas, making the state  
             vulnerable to supply and price fluctuations and costing more  
             than $9 billion per year in lost revenues and jobs as those  
             jobs are outsourced to other states and to Canada.

             "Renewable gas made from organic waste can significantly cut  
             greenhouse gas emissions and landfilling.  Increasing the use  
             of renewable gas will create jobs and economic productivity,  
             and strengthen California's energy security."

          2) Confusing definitions.

             a)    Definition of biogas and biomethane for CPUC standards.  
                 Under AB 1900 (Gatto, Chesbro and Hernández, Chapter 602,  
                Statutes of 2012), CPUC was required to develop health and  
                safety standards for biomethane for injection into the  
                pipeline.  AB 1900 defined biogas as gas produced from the  
                anaerobic decomposition of organic material and defined  
                "biomethane" as biogas that meets the health and safety  
                standards developed by the CPUC for injection into the  
                pipeline. 

                SB 1043 amends both of these definitions.  This bill  
                defines biogas as gas that is produced from organic waste  
                through anaerobic digestion or eligible conversion  
                technologies, consistent with Section 40106 of the Public  
                Resources Code.  Section 40106 of the Public Resources  
                Code specifies that "biomass conversion" is the production  
                of energy through the combustion, or thermal  
                non-combustion conversion, of green waste. 

                The current statutory definition of biogas is very  
                broad-gas produced when organic matter decomposes without  
                oxygen.  AB 1043 narrows the definition to specify  
                technologies necessary for the production of biogas,  
                namely anaerobic digestion, and conversion technologies.   
                The new definition in the bill references a section of  
                code that includes combustion as an eligible "conversion"  
                technology.  However, the gas produced when organic  








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                material is burned is simply steam and CO2, and is not of  
                any use as a fuel. 

                An amendment is needed to specify that biogas means gas  
                produced from organic waste through anaerobic digestion,  
                or eligible noncombustion thermal conversion technologies,  
                consistent with Section 40106 of the Public Resources  
                Code. 
                
                SB 1043 also strikes the current definition of biomethane  
                as a biogas meeting CPUC health and safety standards for  
                pipeline injection, and instead defines biomethane as  
                methane derived from biogas.  

                As noted in the Senate Energy, Utilities and  
                Communications Committee's staff analysis for the bill,  
                the effect of this change is unclear.  The staff analysis  
                states, "Recently, the CPUC, in keeping with statute,  
                adopted standards for injection of biomethane into a  
                pipeline.  The CPUC expresses concern that the changes  
                made by this bill to the definition of "biomethane" could  
                render pipeline injection standards adopted by the CPUC in  
                R.13-02-008 inapplicable or subject to a high degree of  
                uncertainty."

                As a result, that Committee amended the bill to state that  
                nothing with regard to ARB adopting policies for renewable  
                gas is intended to affect the health and safety standards  
                adopted by the CPUC prior to January 1, 2016 for  
                biomethane injection into a common carrier pipeline.

             b)    Definition of biogas and renewable gas for ARB's  
                program.  SB 1043 requires ARB to consider and adopt, as  
                appropriate, policies to increase production and use of  
                "renewable gas." 

                The bill defines renewable gas as either a) biogas or b)  
                synthetic gas generated by an eligible renewable energy  
                resource eligible for credit under the RPS.

                Author amendment.  The author would like to amend the bill  
                to strike the reference to synthetic gas in the bill to  
                address concerns from several organizations representing  
                various agricultural interests that argue synthetic gas  








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                creates additional methane in the environment and, for  
                this reason, should not be given status equal to biogas.
                
                If the author's amendment is taken, "renewable gas" will  
                be defined as simply "biogas."  For clarity, an additional  
                amendment is needed with the author's amendment to strike  
                all references to renewable gas in the bill and replace  
                those references with "biogas."
                 
          3) Protecting health and safety for end users of biogas.  Any  
             policy adopted by ARB under SB 1043 is required to accomplish  
             a number of goals, namely that the policy promote renewable  
             fuels, reduce GHG emissions, divert organics from landfills,  
             reduce pollution, promote forest health, and protect  
             environmental quality of natural and working lands. 

             An amendment is needed to require ARB also ensure the health  
             and safety of any adopted biogas policy. 
          
          4) Biomass conversion, sewage sludge, and compost residue?   
             Biomass conversion in state law means the production of  
             energy (e.g., fuels, electricity, heat) by combustion, or the  
             use of noncombustion thermal conversion technologies of  
             specified biomass, including, agricultural crop residues,  
             bark, lawn, yard, garden clippings, leaves, silvicultural  
             residue, tree and brush pruning, wood, wood chips, and wood  
                                    waste and nonrecyclable pulp or nonrecyclable paper  
             materials, when those materials are separated from other  
             solid waste. 

             Current law requires jurisdictions to divert 50% of solid  
             waste from landfill disposal or transformation (combustion of  
             municipal solid waste) through source reduction, recycling,  
             and composting activities.  CalRecycle calculates whether  
             this requirement is met by tracking disposal at  
             transformation facilities and landfills.  

             Biomass conversion is excluded from the definition of  
             transformation, and therefore, biomass that is combusted or  
             "converted" at a biomass conversion facility is not counted  
             as disposal.  

             SB 1043 strikes the prohibition for sewage sludge as an  
             eligible biomass conversion feedstock.  This change may allow  








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             jurisdictions to receive diversion credit for burning sewage  
             sludge. 

             An amendment is needed to add back in to the bill sewage  
             sludge as a material not eligible as a feedstock under the  
             definition of "biomass conversion." 
             
             SB 1043 also includes byproducts or residue from composting  
             as an eligible biomass conversion feedstock. 

             It is not clear what types of materials constitute byproducts  
             or residue from composting.  These materials could consist of  
             anything left over after the composting process, and may  
             include plastics, glass, and other residual wastes.   
             Combustion of these wastes would not be "biomass" conversion,  
             but instead would be combustion of materials typically  
             designated as municipal solid waste. 

             An amendment is needed to strike "byproducts and residue from  
             composting" from the definition of biomass conversion. 
             


          5) Some overlap and potential timing issues with SB 1153  
             (Cannella).  SB 1153 (Cannella), also being considered by the  
             Committee at today's hearing, requires ARB, as a part of the  
             update to the AB 32 Scoping Plan, to provide a comprehensive  
             overview of state efforts to encourage the development of  
             instate biomethane and renewable natural gas and evaluate  
             policy options to overcoming barriers or challenges for its  
             use.  The Scoping Plan is currently being updated by ARB to  
             incorporate the Governor's 2030 midterm target for GHG  
             emissions in Executive Order (EO) B-30-15.  However, it is  
             not clear that the provisions of SB 1153, if approved, will  
             be incorporated into the Scoping Plan before ARB finishes the  
             update pursuant to the Governor's EO.  In that case, the  
             study outlined in SB 1153 may not be included in the Scoping  
             Plan until the next update five years from now.

             SB 1043 requires ARB to consider, and adopt as appropriate,  
             policies to significantly increase the sustainable production  
             and use of renewable gas.  If the bill is passed by the  
             Legislature and signed by the Governor, SB 1043's provisions  
             will go into effect January 1, 2017.








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             Should the Committee deem both bills necessary, the authors  
             should work to address potential issues associated with the  
             timing of the evaluation in the Scoping Plan in SB 1153  
             (Cannella) and the activities required under this bill.  

            Related/Prior Legislation
          
          SB 1153 (Cannella) would require ARB, in consultation with other  
          state entities, as part of the AB 32 Scoping Plan update, to  
          perform an overview of state efforts to encourage the  
          development of instate biomethane and renewable natural gas. The  
          bill is pending consideration by this committee.

          SB 687 (Allen, 2015) would have established the renewable gas  
          standard requiring all natural gas sellers to provide to  
          California retail end-use customers increasing amounts of  
          "renewable gas," so that, by January 1, 2030, at least 10% of  
          the natural gas supplied is "renewable gas."  The bill passed  
          this committee on a vote of 7 to 3 and was held on suspense by  
          the Senate Committee on Appropriations.

          AB 2206 (Williams) requests that the California Council on  
          Science and Technology study the heating value and siloxane  
          specifications for biomethane to be injected into common carrier  
          gas pipelines.  The bill is pending consideration by the  
          Assembly Natural Resources Committee on April 18, 2016.

          AB 2773 (Quirk) requires CPUC to modify its technical standards  
          for biomethane injected into a common carrier pipeline.  The  
          bill is pending consideration by the Assembly Committee on  
          Utilities and Commerce on April 13, 2016.

          AB 2313 (Williams) requires the CPUC to modify its monetary  
          incentive program for biomethane projects.  The bill is pending  
          consideration by the Assembly Committee on Natural Resources.

          AB 577 (Bonilla, 2015) would have required the CEC to develop  
          and implement a grant program for projects related to biomethane  
          production.  The bill was held on suspense by the Senate  
          Committee on Appropriations.

          AB 1900 (Gatto, Chapter 602, Statutes of 2012) directed the CPUC  
          to identify landfill gas constituents, develop testing protocols  








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          for landfill gas injected into common carrier pipelines, adopt  
          standards for biomethane to ensure pipeline safety and  
          integrity, and adopt rules to ensure open access to the gas  
          pipeline system.  

          AB 2196 (Chesbro, Chapter 605, Statutes of 2012) ensures that  
          biogas qualifies for RPS credit, provided its production,  
          delivery and use meet certain conditions.

          SB 1122 (Rubio, Chapter 612, Statutes of 2012) required IOUs to  
          collectively procure at least 250 MW of generation eligible for  
          the RPS from bioenergy generation project, including biogas  
          projects.

          DOUBLE REFERRAL:  

            This measure was heard in Senate Energy, Utilities and  
          Communications Committee on April 5, 2015, and passed out of  
          committee with a vote of 7-0.

          SOURCE:                    Bioenergy Association of California
           
           SUPPORT:               

          American Biogas Council
          Atlas ReFuel
          Bioenergy Association of California
          City of Fresno
          Clean Energy
          Climate Resolve
          Coalition for Clean Air
          CR&R
          Environmental Defense Fund
          Inland Empire Disposal Association
          Kern Refuse Disposal, Inc.
          Los Angeles County Waste Management Association
          Pacific Forest Trust
          Sanitation Districts of Los Angeles County
          Solid Waste Association of Orange County
          TSS Consultants
          Victor Valley Wastewater Reclamation Authority
          West Biofuels
           
           OPPOSITION:    








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          Agricultural Energy Consumers Association
          Agricultural Council of California
          Association of California Egg Farmers
          California Dairies Inc.
          California Farm Bureau Federation
          California Forestry Association
          California Grain & Feed Association
          California Poultry Federation
          Center for Biological Diversity
          Dairy Farmers of America
          Dairy Institute of California
          Milk Producers Council
          Western United Dairymen
           
           ARGUMENTS IN  
          SUPPORT:    Supporters state that the biogas industry offers
          cost-effective technologies and projects that convert resources  
                         to renewable
          electricity and renewable fuels to lessen dependence on foreign  
                         energy, increase
          renewable energy's contribution to meeting our nation's energy  
                         needs, and to build
          a home-grown bioenergy industry that creates jobs and wealth.   
                         They note that SB
          1043 will fill an important gap in California' clean energy and  
                         climate policies by 
          requiring the state to begin to diversify and decarbonize the  
                         gas sector. 
           
           ARGUMENTS IN  
          OPPOSITION:    A coalition of agricultural interests oppose this  
          bill, contending it better policy to encourage biogas production  
          and use through financial incentives, as opposed to new  
          mandates.  The coalition notes that conventional natural gas  
          costs significantly less than renewable gas, and that the bill  
          could cost users considerable amounts of money.  The coalition  
          also states it is inappropriate to put biogas and synthetic gas  
          on equal footing since, the coalition contends, the latter  
          releases methane into the atmosphere. The California Forestry  
          Association also writes in opposition, arguing this bill's  
          provisions regarding biomass should allow use of forest material  
          that meets all requirements of the law. 









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