Comment Log Display

December 15, 2014



Ms. Mary D. Nichols
Chairman, California Air Resources Board
P.O. Box 2815 
Sacramento, CA 95812

Subject:	LCFS Re-authorization and CA-GREET 2.0 Model.


Dear Chairman Nichols:

Clean Energy would like to thank the California Air Resources Board
(ARB) staff for allowing us the opportunity to comment on staff’s
most recent updates to the proposed CA-GREET 2.0 Model.  Clean
Energy – an original supporter of the Low Carbon Fuel Standard
(LCFS) – respectfully requests that the ARB Governing Board at
their February 2015 meeting:

1.	Re-authorize the Low Carbon Fuel Standard (LCFS);
2.	Continue with CA-GREET 1.8b until CA-GREET 2.0 can be further
reviewed and vetted in a public process.

We understand staff is experiencing a significant amount of
pressure to prepare and deliver an LCFS re-authorization package
and a CA-GREET 2.0 update in time for the February Board meeting. 
This daunting task on staff with limited resources is not lost on
us, and we are appreciative of their agreements to participate in
meetings, accept phone calls and respond to e-mails in a timely
manner.  We appreciate their interest in our concerns and comments.


That being said, the condensed timeline for stakeholders to comment
by December 15 after the CA-GREET 2.0 model was released on
December 2 has been extremely challenging and pose a serious risk
of key information being omitted or ignored. We are concerned by
both the speed and limited public process.  As you know, we learned
of the potential and significant increases in carbon intensity
values for compressed natural gas (CNG), liquefied natural gas
(LNG) and renewable natural gas (RNG) with little detail behind
those numbers in late August.  It was only in October that we were
able to look at a draft of the proposed CA-GREET 2.0 model and were
given approximately 10 business days to review staff’s work. 
Unfortunately, but perhaps not surprisingly given limited staff
bandwidth, substantial model and input errors were identified that
still need to be addressed.  Through subsequent discussions with
staff, we were able to make some collaborative progress to improve
the model, but more needs to be done.

On December 2, ARB staff released its second and latest version of
the proposed CA-GREET 2.0 model, providing even less time for
public input, and without time for discussions with staff prior to
the 45-day period which starts on Tuesday, December 16 when the
package will be submitted to the Office of Administrative Law.

One of our primary concerns is the public release in CA-GREET 2.0
of carbon intensity numbers for CNG, LNG, and RNG that are
questionable at best. The data source is just one study, from
Sweden, that compares landfill to anaerobic digestion and of which
is not comparable to systems used in the United States. Staff has
explained the numbers are “illustrative” only, are buried on the
last page of Appendix B, and are not posted anywhere else including
in a proposed regulation or web page.  

While the posting of these numbers are located in only one place,
we are concerned about the characterization of our industry between
now and the proposed implementation date of January 1, 2016. With
such a long timeframe, we are puzzled as to why it is even
necessary for ARB staff to submit a draft model for ARB Board
approval which will continue to be subject to further modification
via public process.    And any documents released by the ARB will
be carefully scrutinized by the industry and subsequent decisions
will be made that could wreak needless havoc. The ARB documents are
often perceived to be what decisions might be likely in the near
future. Carbon intensity numbers without scientific validity – even
considered illustrative at best - and could very well be changed
with the introduction of new studies over the next six months,
could significantly cause alarm and needlessly impact the
marketplace. Therefore, to avoid the problems associated with using
premature or inaccurate carbon intensity numbers, request the
Board:

•	Continue to use the baseline carbon intensity numbers from
CA-GREET 1.8b as a prudent, responsible, and scientifically valid
method forward until these numbers are deemed inadequate;
•	That the Board adopt a resolution that ARB will continue working
to determine and utilize scientifically valid carbon intensity
numbers;
•	That ARB provide ample opportunity for the public to review and
comment on existing and proposed scientific studies – this could
include being done via working groups and workshops.

It is also important to summarize the key problems of the CA-GREET
2.0 Model as outlined in a report issued by ICF International .
This is further evidence much more work needs to be done before it
can be adopted. Please consider several of the key problems:

•	Use of an arbitrary application rate of RNG leakage at
landfills;
•	Application of outdated emission factors from MOBILE6;
•	Fugitive methane emissions do not represent California
pipelines;
•	Distance needs to  be accounted when discussing transmission
versus distribution fugitive emissions;
•	In updates to electricity and hydrogen pathways, there is a
coding error in the spreadsheet model resulting in the mismatching
of NERC and eGRID regions; and,
•	Electricity values need to be adjusted appropriately to reduce
the carbon intensity number when considering multiple pathways
compression.

Thank you for considering our views.  We look forward to working
with you as the process continues