1. In reference to the
slide below:
a. Methane
GWP: According to the UN IPCC latest report as well as the
Methane Cap regulations endorsed by 197 countries including the US
at COP27, Methane is considered to have a GWP of 86 X CO2 over the
next 20 years. Evaluating Methane global warming potential
over the next 20 years is the ONLY way to accurately evaluate the
impact of Methane considering the near term objective of the State
of CA and of the US to lower CO2 emissions by 50% in 2030 .
Yet, the CARB uses a GWP of 25 X CO2 for Methane based on a
100 year impact. This is contradictory to all current
scientific notation because Methane dissipate over the twenty year
timeframe and create its most harmful impact to the Global warming
during the first 20 years, hence it is no universally considered to
have a GWP of 85 X CO2.
We highly
recommend that CARB adopt the same standards as the US Federal Govt
and the UN IPCC in this regards to evaluate Methnae GWP over 20
years and not over 100 years.
b. Methane
Avoidance credits: There have been many applications to CARB
to accept environmental attributes ( EAs ) from biomethane and use
these EAs to convert fuels in the State into carbon negative H2
using EAs from biomethane created in dairy farms and landfills from
other states. This is highly unusual and have created
unusually low carbon negative credits in the State of CA while
these biomethane are located in other states, and crowding out
opportunities for companies generating carbon negative Hydrogen and
fuels in CA.
c. BECS:
BioEnergy with Carbon Capture and Sequestration was presented
by CEC/CARB to be one of the major tool to reduce CO2 by using
carbon neutral biomass energy with carbon capture and sequestration
which will lead to Carbon Negative Hydroen and energy. This
should be incentivized with higher LCFS credits as additional costs
must be incurred for the CCS on BioEnergy projects.
We
recommend that Methane avoidance credits should only be allowed if
the biomethane is created or avoided IN STATE inside California in
order earn LCFS credits from CARB. We Further recommend clear
pathways for BECS and increased LCFS benefits.
2. Book and
Claim: Book and claim has been approved for RECs to use for
the production of hydrogen from electrolysis. This allows
hydrogen to be produced from non renewable power using grid power
with book and claim. To be consistent, similar book and claim
for RECs should also be allowed for the production of Hydrogen from
the thermal conversion of biogenic waste and biomass.
3. Carbon Capture and
Sequestration: while CCS is a big component of CARB policy, there
are tremendous obstacles for CCS to be implemented in CA due to the
lack of certified Sequestration sites, nor logistics to facilitate
the sequestration of CO2 in the State.
We
recommend that CARB fast track several sites for CO2 sequestration
in the STate and provide clear incentives for the infrastructure
and logistics development to facilitate CCS in the
State.
Dr.Robert T.Do
Chief Executive Officer
SGH2 Energy Global