Comment Log Display

Re: Appendix A to the Regulation for the Mandatory Reporting of
Greenhouse Gas Emissions - Comments by 
David L. Hagen, May 17, 2008
61485 CR 13, Goshen IN 46526
		
1	Exclude Biomass Use
	The prescriptions for reporting biomass fuels in this document
appear onerous and heavy handed. They act in direct opposition to
the intent of the legislation to promote sustainable energy use.
Recommend deleting ALL reporting of biomass, or at least
excluding
ALL  biomass use less then 25,000 metric tons/year. E.g., on page
A-32 (2), exclude biomass.
	On p A-27 (9), is ±5% appropriate for biomass and landfill gas?
Varying moisture content and variations in land fill gas can give
heating value variations far higher than this. Both are nominally
renewable resources and nominally do not contribute to increasing
atmospheric CO2 on a steady state basis. E.g., on pages A-103 (2)
and (3). It would appear important to evaluate the fossil fuel
based carbon dioxide and exclude the biomass based carbon
dioxide.

2	Uncertainty goals rather than prescription
The document focuses on prescription rather than on the end goal
of the desired “accuracy” or uncertainty. Recommend specifying a
desired long term uncertainty goal as a function of size and
fossil vs biomass. Then let operators select frequency based on
the stability of their instrumentation and feedstock. E.g., A101.
Annual measurements may be overkill for highly stable operations
and equipment. Conversely highly variable operations and poor
quality equipment may require more frequent adjustments and
calibration.

3	Staged verification: 
The mandated prescription requiring all operators to obtain
verification during the same period with gaps of two years in
between will result in an onerous boom/bust work and profit cycle
for verification operators. Recommend the example set in the
Senate of 1/3 of locations being tested in each year of a three
year cycle. Allow operators to select which year to verify on a
first come first serve basis.

4	Fuel & biomass testing
The rigid testing procedure to evaluate fuel value appears heavy
handed and without reference to the overall uncertainty desired.
Recommend specifying a desired uncertainty, and allow operators
to
select the frequency of testing according to their fuel
variability
and their relative size. E.g., allow small operators to use
standard fuel values or only test occasionally. Allow operators
to
accumulate samples that are then tested on a less frequent basis.
E.g. every quarterly, semi annually or annually for smaller
operators.

5	Size: 25,000 vs 2,500 metric tons
Per ARB resolution 07-54, “3. Annual reporting of GHG emissions .
. .sources that emit over 25,000 metric tonnes (sic) per year of
CO2 from stationary source combustion is necessary to include the
most significant California GHG emissions sources.” There are
numerous references to 2,500 metric tons. Recommend correcting
all
these to 25,000 metric tons unless otherwise authorized by the
ARB
or by clear uncertainty guidelines in emissions reporting.

Detailed recommendations & corrections: 
6	Appendix A-3 unit Re: “Tonnes (metric)”. In the United States
the correct term is metric ton. See: "Metric System of
Measurement: Interpretation of the International System of Units
for the United States", Federal Register notice of July 28, 1998,
63 F.R. 40333. See: NIST SP-811, Guide for Use of SI Units, Barry
N. Taylor, 1995.
7	Appendix A-3 Unit Conversions. Re Btu conversion factors. There
are at least five Btu definitions. Specify the temperature or
type
of Btu being specified.
8	Appendix A-3 Unit Conversions. Correct “Kilograms” to
“kilogram”, “Kilometer” to “kilometer”, “Kgf” to “kgf”, etc. Add
“(Mg)” after “Megagrams”.
9	Appendix A-5 Section 4. Specify the time frame for the quantity
threshold. E.g “25,000 metric ton/year threshold” and “2,500
metric ton/year threshold”.
10	Table 3. Correct “Kg” to “kg”.
11	Appendix A-8. Re: significant units in fuel type. All fuels
show two significant figures while Municipal Solid Waste is
listed
to five significant figures and is yet one of the most variable. 
Change to 91 kg CO2/MMBtu.
12	Appendix A-4 95102 Definitions (a) (1) “Accuracy”. 
Accuracy is an informal term. If you wish quantitative results,
this should be changed to “Uncertainty”. See NIST publications
relating to Uncertainty.
“Uncertainty of Measurement Results from NIST”
“Guidelines for Evaluating and Expressing the Uncertainty of NIST
Measurement Results”
See Book: Measurement Uncertainty, 3rd Edition
Measurement Uncertainty: Methods and Applications, Fourth Edition
Ronald H. Dieck, (2006) ISA, ISBN: 1556179154
13	A-5 (11) Add conversion to liters.
14	A-5 (17) Add note that there are four other definitions of
Btu.
15	A-5 (83) Include “bitumen, shale oil.”
16	A-14 (105) Correct “pressure” to “potential difference”. Add
“One Watt is the power equal to one joule of energy per second.”
17	A-15 (115) Correct “Metric tonne” to standard US usage of
“metric ton”. Correct throughout the document and appendix.
See: "Metric System of Measurement: Interpretation of the
International System of Units for the United States", Federal
Register notice of July 28, 1998, 63 F.R. 40333
NIST SP-811, Guide for Use of SI Units, Barry N. Taylor, 1995.
18	A-22 (181) 760 mm is incorrect with 60 deg. F. Correct STP
definition to read:
“Standard conditions” or “Standard Temperature and Pressure”,
unless otherwise designated,  refer to the USA customary value
per
the American Gas Association (herein “STP(68)”) of: “a
temperature
of 15.6 degrees Celsius (68 degrees Fahrenheit) at a pressure of
one atmosphere (101.325 kPa).” Some citations refer to the
Compressed Gas Institute value (herein “STP(60)”) of: “a
temperature of 20 degrees Celsius (60 degrees Fahrenheit) at a
pressure of 762 mm (30") mercury.”  (E.g., designate on page A-97
etc.)
19	A-26 (6). Specify the time frame. E.g., “20,000 metric
tons/year”.
20	A-27 (9). “Accuracy” (as noted above) is not used for
quantitative measures. Correct to “uncertainty”. See “uncertainty
guidelines” at NIST.gov.
21	
A-62	95112. Include “cooling” or Combined Cooling, Heat, and
Power.”