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Comment 9 for LCFS Program Review Advisory Panel (2011) (lcfsadvisorypanel-ws) - 4th Workshop.
First Name: Harvey
Last Name: Eder
Email Address: harveyederpspc@yahoo.com
Affiliation: self & PSPC Public Solar Power Coalition
Subject: RE part 3 of 4 or more testimony CARB LCFS LCA Nat GasEnd of Dr.St. Doc/
Comment:
Attached is the balance of Dr. Jim Stew art paper about Natural Gas last page will follow if possible in submittal 4 of 4 or more Following comments are also submitted for /on the record . As cited in part 2 of 3 or more when branch Chief Richard ??? would not let me/us finish talking at the public meeting in Aug. or July 2011 this is also submitted to the ombudsman as an official complaint. signed Harvey Eder public solar power coalition for self and PSPC. Page 6 0f 6 will follow Dr. Stewart paper under part 4 or 4 or more In his paper he states that in the best of all perfect world a new engine full tuned will burn 98% of the methane /nat, gas with 2 % emitted into the atomosphere etc. In a conversation earlier today Dr. S said in a not new engine 95% world burn with 5% ch4 emittedinto the atmosphere. This is a very conservative number. 3 years ago at a SQAUMD meeting on clean technology held in Long Beach in 2008 ( where TBoon Pickens was the lunch specker who talked abput fracking natural gas and converting vehicles to natural gas throughout the US and puching his proposed Proposition on the Nov Ballot in Calif to do this which was soundly rejected by California voters as was PG&E anti Public Solar Power Prop. in spring 2009 Prop 16 and last years 2010 Prop 23 against our Golbal warming law which this proceeding was initated by in 2006 AB32-the people of Ca. know better and deserve a resources agency/epa etc CARB that legally does it's job and uses the best data available to impliment the LCFS ( and it's trading law and CI studies etc. not bought out oil and gas industry people doing there bidding. Gas is better left in the ground. and immediatesolar conversion is needed now! zIn 09 in LBeach staff from International Harvester said that they tested a nat gas engine and that 15% of the methane was emitted into the atmosphere un burned. CARB SCD state and Fed EPA , CEC and DOE need to do the studies of these buses in D.C that were tested 5/6 years ago etc and get the facts data and figures on whats out there and not push "what I called at the CARBs LCFS Expert Wk Group the elechant in the room" that if being ignored. The N.ice cap if melting and all the epople of Ca. get is Bus as Usual. Maybe more that 15% of methane is leaking and being emitted into the Atmosphere with a GWP of 34 to 105 There was a study done in April of 2011 that said fracked natural gas had a higher ghg emission than coalat Cornell University a copy of this I/we submitted to CSD Randal Pasak and Henry Hogo etc. and upon request if was sent to John Courtis requesting that this be delt with this year rather in 20123 or 2014 plus. when we're converting to natural gas. All of the Biomas fig. still have3 to be looked at not pushed through llike the nat. gas is now with 2 days before Ch 2 and % submittals poped up on the WEB by CARB staff !!!Dr. David R. Atkinson Prof of Ecology and Environmental Biology at Cornel and Dwight C. Baum Prof. of Engerneering and Renee4 Santoro a reasarch Tech on ecology and evolutionary biology published this paper I /we will try to submitt it and related info by the 5 pm deadline for LCFS etc today. including a May 4, 2010 letter from the Council of Scdientific Society Presidentd Wash D. 202 872-4452 etc.Combining the Two Effects Produces Much More Net GHG Emissions for Energy Recovery In addition to the increase in fugitive emissions, there is the effect reported above that wet landfills produce 2.3 – 4.7 times more methane than dry ones. If we combine these two observed effects, the net result would be 3.8 - 7.8 times more net GHG emissions for energy recovery compared to flaring (a result that applies irrespective of the value of the GHG multiplier for methane). The charts in Figure 6 indicate the actual global warming savings using the captured methane from energy recovery to replace the burning of fossil methane are very small (0.0007 tons of carbon dioxide equivalent per typical ton of municipal solid waste (MSW)), much less than the overall impacts of the escaping methane. The left chart shows a net increase of GHG emissions of 0.034 CO2 equivalent tons/ MSW ton using the old (1995) multiplier of 21 (which is still used by the US EPA for “consistency”). The right chart shows a net increase of GHG emissions of 0.172 CO2 equivalent tons/MSW ton using the latest (2009) multiplier of 105 over the next critical 20 years. Below the large right red bars for energy recovery in both figures, there is a very tiny blue line (that looks almost like a shadow) that represents the amount of benefit from offsetting the use of fossil fuels, which in each case is only 0.0007 tons of carbon dioxide equivalent per typical ton of MSW. 21 Patrick Sullivan, SCS Engineers, The Importance of Landfill Gas Capture and Utilization in the U.S., April 2010, p. 28-30. (http://www.scsengineers.com/Papers/Sullivan_Importance_of_LFG_Capture_and_Utilization_in_the_US.pdf) 22 It is very unfortunate that EPA 40 CFR Part 98 allows the use of a default 99% destruction efficiency for methane for all types of LFG combustion devices, including engines, ignoring this large GHG impact. 23 McCommas Bluff LFGTE Project, Voluntary Carbon Standard Assessment, Jan. 2010, by Blue Source LLC, available from the author, Annika Colson, (212) 253-5348, acolston@bluesource.com Jim Stewart, PhD Landfill gas to energy GHG impacts July 23, 2011 6
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Date and Time Comment Was Submitted: 2011-10-21 14:36:16
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