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Comment 1 for General comments on ARB staff's overall approach on interim GHG significance thresholds under the CEQA. (ceqa-general-ws) - 1st Workshop.
First Name: Don
Last Name: Nelson
Email Address: dnelson@rockenergyllc.com
Affiliation: Rock Energy, LLC
Subject: CO2 significance threshold for heavy oil operations
Comment:
Please do not adopt your planned significance threshold of 7,000 metric tons of CO2 for California heavy oil projects. Please consider that huge amounts of undeveloped heavy oil reserves remain in California but these deposits must be heated with injection of steam from steam boilers to unlock the oil. The volume of CO2 created from California heavy oil operations was much, much higher 20 years ago. I hope you can make an exception for California heavy oil operations that uses a CO2 significance threshold based on CO2 levels from 20 years ago. If you held other industries to levels from 20 years ago, we can make much progress on reduction of CO2 emissions. Thank you!
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Date and Time Comment Was Submitted: 2008-10-27 10:38:32
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