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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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