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Comment 2 for Possible Revisions to the Cap-and-Trade Regulation (ct-3-2-18-wkshp-ws) - 1st Workshop.


First Name: Andrew
Last Name: Craig
Email Address: acraig@calbioenergy.com
Affiliation: California Bioenergy LLC

Subject: GWP of Methane
Comment:
CalBio proposes that the definition of Global Warming Potential be
updated to be consistent with the updated definition provided in
the Mandatory Reporting Regulation: 

The language from the MRR is:
"Global warming potential" or "GWP" means the ratio of the time-
integrated radiative forcing from the instantaneous release of one
kilogram of a trace substance relative to that of one kilogram of a
reference gas, i.e., CO2.  For 2011 through 2020 data years, the
GWP values used for emissions estimation and reporting are as
specified in Table A-1 to Subpart A of Title 40, Code of Federal
Regulations (CFR) Part 98 as published to the Federal Register on
10/30/2009.  For data years 2021 and onward, the GWP values are as
specified in the Table A-1 to Subpart A of Title 40 Code of Federal
Regulations Part 98 as published to the CFR on 12/11/2014, which is
hereby incorporated by reference.

Thanks,
Andrew Craig

Attachment:

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Date and Time Comment Was Submitted: 2018-03-12 14:30:59



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