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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
AffiliationLife Cycle Associates
SubjectTemp 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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