| Comment | Howdy CARB,
Cc: "Harvey Eder" Message contains
attachments4 Files (2467KB) | Download
AllEmissionsCNG&DieselBuses.pdfShindell-Methane34&105.pdfGHG
footprint of natural gas from shale
formations.pdfLandfill-gas-to-energyIncreasesGHG-Jul11.pdfCorrect
the LCFS GREET to account for fugitive natural gas emissions
The GREET standards used for the LCFS do not correctly account for
fugitive natural gas emissions and other GHG emissions.
1. CARB still uses a methane carbon intensity of 25 times CO2,
instead of the latest science saying it is 34 over 100 years or 105
over the next crucial 20 years, as shown in the paper by Drew T.
Shindell, et al., “Improved Attribution of Climate Forcing to
Emissions,” Science 326, 716 (2009). (attached) When will CARB use
the latest science?
2. The latest science says that methane produced by fracking has
more fugitive emissions than conventional natural gas, which should
be included in any LCFS for methane produced by fracking. The paper
by Howarth, et al., says fracking “methane emissions are at least
30% more than and perhaps more than twice as great as those from
conventional gas..) See attached paper, “Methane and the
greenhouse-gas footprint of natural gas from shale formations,”
Climatic Change (2011) 106:679–690, downloadable from: DOI
10.1007/s10584-011-0061-5
3. GHG emissions from aged natural gas engines are considerably
more than new engines, and should be included in the calculations.
The paper by Melendez, et al., indicates in Fig. 14 on p. 22 that
older natural gas engines could emit as much as 50% more emissions
than new buses. See attached paper, “Emission Testing of Washington
Metropolitan Area Transit Authority (WMATA) Natural Gas and Diesel
Transit Buses,” downloadable from:
http://www.afdc.energy.gov/afdc/pdfs/36355.pdf
4. CARB has failed to account for even the EPA acknowledged 75%
fugitive emissions related to methane from landfills (and it is
probably more than 75% over the full life of a landfill), as
compared to methane from contained anaerobic digesters of waste
with 0 % fugitive emissions. See attached paper by Jim R. Stewart,
“Landfill Gas-to-Energy Projects May Release More Greenhouse Gases
Than Flaring,”
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Attached is information that has been submitted to CARB staff
over the past several months and several years for GHG
LCFS from natural gas that needs bo be addressed now in this
review.
More data will be submitted.
This is off by orders of magnatude when combinedand at the
very least by several factors. Example, in CARB Februaur 27, 2009
GREET for CNG a "placeholder" fogure of 0.0375 grams methane per
mile is used for natural gas emissions while the CARB papers send
for review of this issue on Washington D.C cng buses sent by
Michael Benjamin & visa vie Cody Livingston documents from 10 to
17+ grams ch4 emitted per mile. More recently the April 2010 study
of natural gas GHG methane emissions probvided by SCAQMD has data
of from 40 to 100 grams methane/CH4 per mile emitted for heavy duty
vehicles. Suspeciously the same number was used for nitrous oxide
N2O of 0.0375 grams emitted per mile.This is off by over 100 to
1000 times the number used by CARB staff and nothing was done about
it when brought up to staff on the record or by the Expert Work
Group ( several times ). This will all be documented in detail in
future litigation following CARBs Boards decision not addressing
these issues.
Thanks, take care
Harvey Eder/ Public Solar Power Coalition
PS Natural Gas is the main competition for solar electric and solar
hydrogen and our resources are limited and increasingly scarce.
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