4. Comments on Petition

Comments on the petition were filed by BioFuels Energy LLC (BFE), FuelCell Energy Inc. (FCE), Microgy Inc., and PG&E on behalf of the SGIP PAs.

BFE, FCE and Microgy support the petition and urge its adoption to propel increased use of renewable fuels and deployment of new fuel cell DG systems in California. FCE notes that according to the recent SGIP Year 7 Impact Report, fuel cells operated on biogas have demonstrated high capacity factors while simultaneously delivering significant reductions in greenhouse gas (GHG) emissions.

PG&E comments that the PAs support the Bloom proposal, but outline three suggested modifications. We discuss these modifications in the discussion below.