GPI GPI recognizes that major producers of biogas are interested in processing their biogas into biomethane and injecting that biomethane into common carrier pipelines. This interest is being driven by environmental regulations which restrict the ability to use biogas to run small engines. GPI notes that the pipeline injection of processed biomethane is expensive because of the conversion process to turn biogas into biomethane, and the energy needed to compress the biomethane to pipeline pressure. GPI contends that the successful implementation of AB 1900 depends on keeping the compliance costs associated with biomethane injection as low as possible. GPI suggests that reasonable rules and regulations be formulated that minimize the burden on the biomethane suppliers, including the monitoring, testing, reporting and recordkeeping requirements. GPI opposes the proposal of the four utilities to test the biogas, rather than the processed biomethane that will be injected into the pipeline. GPI that concurrent with the injection of biomethane into the pipelines, the utilities are proposing to add upgrades to the pipeline system, such as installing various probes and corrosion coupons. GPI questions whether such upgrades are needed at this time, and believes it would be counterproductive to tie the system upgrades to the AB 1900 testing requirements. GPI contends that biomethane is a renewable fuel, the Commission should work with CARB and other agencies to ensure that whatever reporting requirements are adopted for biomethane, should be capable of being used to
GPI GPI recognizes that major producers of biogas are interested in processing their biogas into biomethane and injecting that biomethane into common carrier pipelines. This interest is being driven by environmental regulations which restrict the ability to use biogas to run small engines. GPI notes that the pipeline injection of processed biomethane is expensive because of the conversion process to turn biogas into biomethane, and the energy needed to compress the biomethane to pipeline pressure. GPI contends that the successful implementation of AB 1900 depends on keeping the compliance costs associated with biomethane injection as low as possible. GPI suggests that reasonable rules and regulations be formulated that minimize the burden on the biomethane suppliers, including the monitoring, testing, reporting and recordkeeping requirements. GPI opposes the proposal of the four utilities to test the biogas, rather than the processed biomethane that will be injected into the pipeline. GPI that concurrent with the injection of biomethane into the pipelines, the utilities are proposing to add upgrades to the pipeline system, such as installing various probes and corrosion coupons. GPI questions whether such upgrades are needed at this time, and believes it would be counterproductive to tie the system upgrades to the AB 1900 testing requirements. GPI contends that biomethane is a renewable fuel, the Commission should work with CARB and other agencies to ensure that whatever reporting requirements are adopted for biomethane, should be capable of being used to