| Comment | Currently, SGH2 Energy is in the process of developing and
building
a green hydrogen plant from biomass/waste non-recyclable paper.
1. The facility will be requiring power to run the plant. We would
need about 6 -8 MW of power for the plant operation, which is
standard processing equipment like pumps, compressors, sensors,
and
electronics. And this power is not used for electrolytic H2
production. We request that we use book and claim of renewable
energy credits to cover for this power consumption. For
comparison,
an electrolytic hydrogen production plant to produce similar
hydrogen as our plant (4,000,000 Kg), would require a 100 MW of
solar panels.
2. Methane - global warming potential (GWP) should be calculated
based on 20 years. Methane being a potent greenhouse gas which
traps heat in the atmosphere and contributes to climate change.
Over a 20-year period, methane's GWP is between 84 and 87, meaning
that one ton of methane emitted today has the same GWP as 84 to 87
tons of carbon dioxide over the next 20 years. And methane also
has
a short half-life, and its impact is only in the first 20 years.
Therefore, there is no reason to calculate its GWP over 100 years.
3. According to EPA, landfill gas when captured is not more than
50%. Not all California Landfills are capped for gas. Therefore,
we
recommend CARB use EPA statistic and only 50% of landfill gas can
be captured.
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