Comment Log Display

Correct the LCFS GREET to account for fugitive natural gas
emissions

The GREET standards used for the LCFS do not correctly account for
fugitive natural gas emissions and other GHG emissions.

1. CARB still uses a methane carbon intensity of 25 times CO2,
instead of the latest science saying it is 34 over 100 years or 105
over the next crucial 20 years, as shown in the paper by Drew T.
Shindell, et al., “Improved Attribution of Climate Forcing to
Emissions,” Science 326, 716 (2009). (attached) When will CARB use
the latest science?

2. The latest science says that methane produced by fracking has
more fugitive emissions than conventional natural gas, which should
be included in any LCFS for methane produced by fracking. The paper
by Howarth, et al., says fracking “methane emissions are at least
30% more than and perhaps more than twice as great as those from
conventional gas..) See attached paper, “Methane and the
greenhouse-gas footprint of natural gas from shale formations,”
Climatic Change (2011) 106:679–690, downloadable from: DOI
10.1007/s10584-011-0061-5

3. GHG emissions from aged natural gas engines are considerably
more than new engines, and should be included in the calculations.
The paper by Melendez, et al., indicates in Fig. 14 on p. 22 that
older natural gas engines could emit as much as 50% more emissions
than new buses. See attached paper, “Emission Testing of Washington
Metropolitan Area Transit Authority (WMATA) Natural Gas and Diesel
Transit Buses,” downloadable from:
http://www.afdc.energy.gov/afdc/pdfs/36355.pdf

4. CARB has failed to account for even the EPA acknowledged 75%
fugitive emissions related to methane from landfills (and it is
probably more than 75% over the full life of a landfill), as
compared to methane from contained anaerobic digesters of waste
with 0 % fugitive emissions. See attached paper by Jim R. Stewart,
“Landfill Gas-to-Energy Projects May Release More Greenhouse Gases
Than Flaring,”