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Comment 1 for Comments on Crude Oil analysis for LCFS (lcfs-crude-oil-ws) - 1st Workshop.
First Name: Catherine
Last Name: Price
Email Address: catherine.price@shell.com
Affiliation: Shell
Subject: Albian Heavy Synthetic GHG intensity in LCFS 2013 crude baseline
Comment:
We have reviewed the recently published draft calculation of the California Industry Average Crude Carbon Intensity for 2013. We have noted that GHG intensity of AHS is reported in this document as 21.02 gCO2e/MJ, a value calculated with OPGEE 1.0. We believe that this value of 21.02 gCO2e/MJ contains an error due to higher and lower heating values being confused when coefficients from Canada’s GHGenius model (which works in HHV) were used unchanged in California’s OPGEE 1.0 model (which works in LHV). My colleague Trevor Stephenson engaged in some communication on this matter with Adam Brandt which resulted in the OPGEE 1.0 model being corrected. The resulting updated value of 19.86 gCO2e/MJ was published in the minutes of CARB’s “LCFS Proposed 2013 Regulatory Amendments” workshop of March 5th, 2013 (see http://www.arb.ca.gov/fuels/lcfs/regamend13/Draft_Crude_CI_Values_%28OPGEEv1.1_DraftA%29_March_4_2013.pdf). Please could you confirm that this value will be corrected in the 2013 calculation and in upcoming regulatory updates to adopt the latest “OPGEE” model (v. 1.1) going forward? Thank you very much. Kind regards, Catherine
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Date and Time Comment Was Submitted: 2014-06-24 03:44:44
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