As we wrestle with climated change mitigation options and policies, we need to have this work replicated in all major oil and gas producing regions. I fear Canada is relying on techniques criticized in this importnat paper. The treatment of natural gas as a transition fuel away from other fossil fuels is called into question as is continued promotion of natural gas use in residential and commercial space and water heating. The Public Utilities Board in Manitoba is considering the process it will use to review the feasiblity test used in the province to test proposed expansions in regulated natural gas use. Manitoba Hydro continues to promote expanded use of nataural gas by its customers. The current feasibility test does not include climate change mitigation measures that are being taken in Manitoba and other parts of Canada let alone any of those that will be in place in 10, 15 or 20 years. This report questions an essential aspect of a serious climate change mitigation policy directed at natural gas use, namely, whether the lifecycle emissions of the fuel are materially understated by limiting consideration to the emissions associated with combustion of the fuel. I am of the view that this report and other works like it support a conclusion that yes, current GHG accounting in the oil patch materially understates natural gas’s contribution to climate change.