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Comment 5 for Provides the public and stakeholders opportunities to provide "informal" public comments as part of ARB's 2013 Scoping Plan Update Workshop Series (2013-sp-update-ws) - 1st Workshop.
First Name: Lee
Last Name: Wallace
Email Address: lwallace@semprautilities.com
Affiliation: Southern California Gas Co. / San Diego
Subject: 2013 Scoping Plan Update Workshop
Comment:
We have been using the 2013 EPA GHG inventory to help address questions we have received about methane emissions. It is the most reliable and accepted source of national data available, and has been issued for 18 years. This year’s report stated, “Overall, natural gas systems emitted 139.6 Tg CO2 Eq. (6,646 Gg) of CH4 in 2011, a 13 percent decrease compared to 1990 emissions (see Table 3-43, Table 3-44, and Table 3-45) and 32.3 Tg CO2 Eq. (32,344 Gg) of non-combustion CO2 in 2011, a 14 percent decrease compared to 1990 emissions (see Table 3-46 and Table 3-47). The decrease in CH4 emissions is due largely to a decrease in emissions from transmission and storage due to increased voluntary reductions and a decrease in distribution emissions due to a decrease in cast iron and unprotected steel pipelines.” Chapter 3, page 56. Here is the link to the entire report: http://www.epa.gov/climatechange/ghgemissions/usinventoryreport.html . We are not referring to the EPA GHG Inventory as the “answer” to the current discussion about methane emissions from the natural gas system. But it does present data about how the natural gas industry performed during a recent period of growing demand for natural gas. The Inventory shows the natural gas system had a steady decline in methane emissions. It also discusses the reasons behind the decline. The report contains a more detailed discussion, but it was primarily voluntary reductions in transmission and storage (e.g. the EPA Natural Gas Star program) and replacement of cast iron and steel pipe. These practices will continue, because there are many reasons we want to reduce leakage, including improved safety, conservation of our product, and of course improvement in the environment. I also wanted to let you know about California legislation, AB 1257 (Bocanegra), we are supporting. The bill would require the California Energy Commission, by January 1, 2015, and every 4 years thereafter, to prepare and submit to the Legislature and Governor a report containing specified information identifying strategies to maximize the benefits obtained from natural gas as an energy source in California. The report will include: (10) Evaluating the incremental beneficial and adverse economic cost and environmental impacts of proposed strategies ,including lifecycle greenhouse gas emissions from production, transportation, and use of natural gas based on authoritative, peer-reviewed, and science-based analysis, or as determined by the State Air Resources Board. We look forward to working with CARB, CEC and other stakeholders to have a public discussion of this and other issues associated with the future of natural gas, whether or not this bill becomes law. If you have further questions, please feel free to contact me. Lee Wallace Environmental Affairs Manager Environmental Affairs Department Southern California Gas Co. / San Diego Gas & Electric Work: 213.244.8851 Cell: 213.215.3787 Fax: 213.244.8254 Email: lwallace@semprautilities.com
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Date and Time Comment Was Submitted: 2013-07-02 15:58:54
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