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Comment 53 for Public Comments for LCFS pathway applications (tier2lcfspathways-ws) - 2nd Workshop.
First Name: Stefan
Last Name: Unnasch
Email Address: unnasch@lifecycleassociates.com
Affiliation: Life Cycle Associates
Subject: Temp FPC for Dairy Biogas to Hydrogen
Comment:
ARB's staff document refers to hydrogen from SMR from LNG. This would indeed be a worst case; however, LH2 plants receive natural gas by pipeline. The change in CI would correspond to Base hydrogen - NG_CI + RNG CI The CI of NG direct use and upstream is 71 g/MJ In ARBs example, the CI would be 185 - 71 - 150 = -36 g/MJ For typical LH2 pathways, 155 - 71 - 150 = -66 g/MJ The average of these two values is -51 g/MJ, which is consistent with the proposed temporary FPC.
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Date and Time Comment Was Submitted: 2020-11-12 08:11:19
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