Comment #1Amendment: Proposed MINHERS Addendum 66f, CO2 Index, Draft PDS-02Page Number: 5.1.2.2.2.1 and 6.4Paragraph / Figure / Table / Note: 2 and 4Comment Intent: Not an ObjectionComment Type: TechnicalComment:Proposed Change:The use of Electric for all regions instead of either a regional average or identical fuel for the reference house will create significant inaccuracies in regions where NG electric Plants exist but oil heating is wide scale. It seems the application of Electric fuel for the reference house is arbitrary and lacking technical data to support a true co2e index.
Comment #2Amendment: Proposed MINHERS Addendum 66f, CO2 Index, Draft PDS-02Page Number: 1Paragraph / Figure / Table / Note: Table 5.1.2(1)Comment Intent: Not an ObjectionComment Type: GeneralComment: NRDC supports the changes. The inclusion of end-to-end methane leakage is important because methane is a powerful greenhouse gases that contributes significantly to global warming when released into the atmosphere. A comparison of emissions impact of various energy sources must use consistent scopes. Accounting for emissions from electricity typically includes emissions from both in-state and out-of-state power plant emissions that produce electricity consumed in a given state. To enable a valid comparison of climate impacts, emissions from methane gas use should include both upstream and behind-the-meter emissions for gas that leaks to the atmosphere uncombusted.
NRDC supports the changes. The inclusion of end-to-end methane leakage is important because methane is a powerful greenhouse gases that contributes significantly to global warming when released into the atmosphere. A comparison of emissions impact of various energy sources must use consistent scopes. Accounting for emissions from electricity typically includes emissions from both in-state and out-of-state power plant emissions that produce electricity consumed in a given state. To enable a valid comparison of climate impacts, emissions from methane gas use should include both upstream and behind-the-meter emissions for gas that leaks to the atmosphere uncombusted.
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