RACE's comments to the California Air Resources Control Board regarding AB32 may be downloaded by clicking on the arrow below.
Our research finds the following:
- The new greenhouse gas
laws only count the emissions coming from a power plant. What happens on the way
to the power plant will not be counted as emissions.
- In the case of LNG,
this amounts to about 5 million tons per year, per LNG terminal, that will go
uncounted. There is one terminal now operating from which California is importing
natural gas; several more are proposed. This is the difference between the
production of domestic and the entire process to import
LNG.
- 5 millions tons per
year is roughly equivalent to the emissions of 1 million
cars.
- There is a
double-standard going on, as the state has elected to count the lifecycle
emissions for transportation fuels.
- There have been several
studies that have detailed this, most notably one from CarnegieMellonUniversity.
- The California State
Lands Commission and Coastal Commission have rejected an LNG terminal on the
grounds that it was in conflict with the new greenhouse gas laws. The Oregon
Department of Energy has acknowledged the same. And even PG&E (a partner in
a proposed LNG project) has acknowledged that the LNG lifecycle does add
significant emissions. Yet the CPUC – which was charged with coming up with the
guidelines for these emissions – has refused to acknowledge this huge loophole.
We now need to bring it up at CARB.
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