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The Sierra Club argues that the proposed Biomethane Tariff by Sempra Utilities is a 'greenwashing' exercise that fails to meet California's incrementality standards for green energy programs. The protest highlights that the tariff would allow the sale of renewable attributes from existing methane sources, potentially including those outside the United States, without ensuring the development of new renewable facilities. Furthermore, the Sierra Club contends that the program lacks a finalized certification protocol and a transparent methodology for calculating greenhouse gas reductions, while potentially incentivizing industrial dairy operations that cause localized air and water pollution. The document suggests that the limited supply of biomethane—estimated at less than four percent of California's total gas demand—should be reserved for hard-to-electrify applications rather than voluntary subscriptions that perpetuate reliance on gas infrastructure.