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APPENDIX "C" 

PUBLIC COMMENTS AND RESPONSES

1. County Sanitation Districts of Los Angeles County (with attachment), 11/02/2009 

2. CARB “No Comment” letter, 11/09/09 

3. County Sanitation Districts of Los Angeles County email, 11/10/2009 
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Public Comment Letter 1 
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District response to Public Comment Letter 1 

1. Per later email correspondence (See public comment #3) regarding potential NOx limits for biogas 

turbines greater than 10MWs, County Sanitation District of Los Angeles obtained feedback from Solar 

Turbines (currently the only biogas turbine manufacturer). Solar Turbines indicated that the largest 

operational biogas turbine is their 10MW Mars100 gas turbine. Accordingly, the County Sanitation 

Districts of Los Angeles was unable to identify any applicable emission data from larger biogas 

turbines. As a result, the Sanitation Districts recommended utilizing existing rule language for biogas 

turbines (i.e., a reference NOx limit of 25ppm for 0.3 to 10 MW). An additional compliance limit has 

been added for turbines which utilize digester gas and/or landfill gas which does not change the NOx or 

CO compliance limit for the size range of turbines identified, merely specifies the fuel technology. 

2. If an owner or operator of a stationary gas turbine is required to install emission control 

equipment for compliance with the rule (see §(F)(1)), an enhanced emission monitoring device shall be 

installed (see §(F)(1)(a)(iii), not limited to CEMS or PEMS, see §(B)(10)). 

3. The AVAQMD is not mandating the use of specific control technologies. 

4. Table 5 in the Technical Report of the Staff Report (Appendix “F”) has been corrected to reflect 

the appropriate proposed limit of 42 ppmv. 

5. The Staff Report has been amended to discuss the significant difficulties and problems associated 

with several turbine control technologies (See Appendix “F” Technical Report, (III)(A)(2)(b)). 

The District appreciates the inclusion of the background information on “Siloxanes in biogases from 

landfills and wastewater digesters.” 
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Comment Letter 2 
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District response to Comment Letter 2 

No comment required. 
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Public Comment Letter 3 
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District response to Public Comment Letter 3 

Please see public comment letter #1, response 1.