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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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