Title: Lower emission limits for biogas engines in SCAQMD as of January 2016

SCAQMD rule for biogas effective 2016 limits emissions to 11 ppmv NOx – 30 ppmv VOC – 250 ppmv CO Stakeholders have commented that the capital and operating costs for cleaning up the biogas are very high and post-combustion control technologies such as Catalytic Oxidation and Selective Catalytic Reduction (SCR) are expensive to install and operate and argued that many of them will resort to flaring as a less costly alternative. Response: •The costs are significant but the environmental benefits are also significant. •Proposed controls are very cost effective. •Reasonable emission reductions such as those from biogas engines needed to meet the ambient air quality standards. •Flaring of a renewable energy source is undesirable. •Biogas flaring, except for a small Greenhouse Gas disbenefit, has a much lower criteria pollutant footprint compared to biogas engines, even considering power that needs to be generated by central power plants.

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