Comment #1Amendment: Proposed MINHERS Addendum 66f, CO2 Index, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: Table 5.1.2(1)Comment Intent: ObjectionComment Type: TechnicalComment: The emisison rates for CO2 in Table 5.1.2(1) are emission rates for combustion only and do not include the upstream pre-combusion rates for household fuels. However, the emission rates for electricity do include the upsteam pre-combustion emission rates for the fuels used to generate electricity. The emision rates for both household combustion fuels and electricity should be based on the same equivalent CO2 emissions. Therefore, the emission rates in Table 5.1.2(1) should be changed from CO2 emision rates to CO2e emision rates. Additionally, the rates in Table 5.1.2(1) should be based on the same 100-year GWP time horizon as are the electricity CO2e emission rates in Section 6 of the proposed Addendum 66f. Proposed Change: Update the emission rates in Table 5.1.2(1) from combustion-only CO2 emission rates to combined combustion and pre-combustion CO2e emission ratesas follows: Fuel Type CO2 CO2e lb/MBtu Natural Gas 117.6 147.3 Fuel Oil #2 161.0 195.9 Liquid Petroleum Gas (LPG) 136.6 177.8
The emisison rates for CO2 in Table 5.1.2(1) are emission rates for combustion only and do not include the upstream pre-combusion rates for household fuels. However, the emission rates for electricity do include the upsteam pre-combustion emission rates for the fuels used to generate electricity. The emision rates for both household combustion fuels and electricity should be based on the same equivalent CO2 emissions. Therefore, the emission rates in Table 5.1.2(1) should be changed from CO2 emision rates to CO2e emision rates. Additionally, the rates in Table 5.1.2(1) should be based on the same 100-year GWP time horizon as are the electricity CO2e emission rates in Section 6 of the proposed Addendum 66f.
Update the emission rates in Table 5.1.2(1) from combustion-only CO2 emission rates to combined combustion and pre-combustion CO2e emission ratesas follows:
Comment #2Amendment: Proposed MINHERS Addendum 66f, CO2 Index, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: Table 5.1.2(1)Comment Intent: ObjectionComment Type: TechnicalComment: Please see the attached file. Proposed Change: Please see the attached file.
Please see the attached file.
Comment #3Amendment: Proposed MINHERS Addendum 66f, CO2 Index, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: Table 5.1.2(1)Comment Intent: ObjectionComment Type: EditorialComment: To be consistent with how abbreviations for million Btu's are expressed in the US. In the US, the abbreviation for 1 million Btu's is MMBtu. MBtu appears to be combining the SI unit of "Mega" with the IP unit of Btu. That combination is not used in publications I have seen. Proposed Change: MBtu Million Btu or MBtu MMBtu
To be consistent with how abbreviations for million Btu's are expressed in the US. In the US, the abbreviation for 1 million Btu's is MMBtu. MBtu appears to be combining the SI unit of "Mega" with the IP unit of Btu. That combination is not used in publications I have seen.
MBtu Million Btu
or
MBtu MMBtu
Comment #4Amendment: Proposed MINHERS Addendum 66f, CO2 Index, Draft PDS-01Page Number: 4Paragraph / Figure / Table / Note: 6.2Comment Intent: ObjectionComment Type: TechnicalComment: It is likely that the Cambium database will be updated on a regular basis. Users should have the option to use the most recent version if it is updated before this addendum is finalized. Proposed Change: calculated using the 2021 or most recent Cambium database....
It is likely that the Cambium database will be updated on a regular basis. Users should have the option to use the most recent version if it is updated before this addendum is finalized.
calculated using the 2021 or most recent Cambium database....
Comment #5Amendment: Proposed MINHERS Addendum 66f, CO2 Index, Draft PDS-01Page Number: 2Paragraph / Figure / Table / Note: Table 5.1.2(1)Comment Intent: ObjectionComment Type: TechnicalComment: Please see the attached file. Proposed Change: Please see the attached file.
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