1. Michael Carleton Paul Gosselink

2. Basic Positions of TxSWANA and Denton & Garland Strongly encourage PUC to adopt rules that will encourage the development of all renewable resources, especially landfill gas and solar, as a way of improving energy security The policy should promote those technologies which can provide cost-effective, environmentally sound alternatives to fossil fuels

3. Landfill Gas Background Decomposition of waste results in the generation of a gas that has an energy value Without control, these gases are emitted into the atmosphere and are a significant source of greenhouse gas emissions in Texas (21 times more harmful than CO2) Control measures available include flaring, energy recovery through electric generation onsite or offsite, offsite industrial fuel or blending with natural gas

4. Benefits of Landfill Gas Technology Significant reduction in emissions Proven technology – 75 MW already in the system Near potential is significant (EPA LMOP program projects that there is 170 MW available in Texas from 53 candidate sites if economic conditions were favorable, this rule can make this a tipping point for moving these projects forward) Does not require new land to be developed Close to markets so a CREZ won’t be required to bring to market In comparison to other renewable resources it represents a low cost option for utilities to achieve the State’s renewable goal Revenues in many cases will benefit local governments

5. TxSWANA, Garland and Denton Recommendations Make landfill gas to energy projects a Tier 1 resource while maintaining the ability of solar to benefit from this classification as well Environmental benefits Economic benefits TxSWANA, Garland and Denton supports Centerpoint’s comments