Comment Log Display

This is part 2 of comments due to lack ot thim on part 1 submitted
2 hours ago today 7/27/11

     The 22MMTons of co2/co2e? reductions cited in the Supplement
to scoping plan FED  cites that LCFS Low Carbon Fuel Standards will
be used in excess of 10MMTons reductions co2/ co2E ? to meet the
total goal of apx. 450MMTco2/co2e? goal for the state by 2020. 
There was ameeting of the LCFS workgroup apx. 1 month ago that
he/PSPC participated in on the phone and gave comments during the
public section of that meeting in Sacramento. The issue of  Cap and
Trade was cited in the meeting and that a sub group of the LCFS
would meet to work on Cap and Trade or market mechanism for
implementing the LCFS Low Carbon Fuel Standard. This is illegal and
the instant proceedings superceed the/ any activity tqaking part in
the LCFS area. It is rather part of this proceedings. The activity
of the LCFS group must stop until these proceedings are resolved.
Aparently there was it was reported in the meeting that there has
been some staff/ structural reorganization of the Cap and Trade
people now some most of all working on LCFS. This is possibler an
end run by CARB to go arould the Courts decision. All of the
numbers have to be revaluated.
    The issue of fuel switching as in the diesel to low sulfer
diesel in the recent pass, and CARB etc et al have been pushing
natural gas as the Clean Alternative Fuel to the tune of $2 billion
 Through the Carl Moyer Program etc. converting buses and now
refues trucks. PSPC has participated in the process before the LCFS
was established by the board or the SCoping plan over the past few
years. raising the issue of ch4/methane as well as nitrous oxide
emissions over the life of vehicles. During the history of the
proceedings over the past few years the only data on this subject
was provided with Michael Benjamin and Cody Livingston providing
info on studins on methane emission eetc,. over the life of a
vehhicle. This was ignored by CARB staff and incorporated into the
record is the communications with staff including cochair of the
LCFS group Jim Duffy who was sent a copy link of , along with John
Courtis
of CARB staff of the Washington D.C study of Metro Buese over
timedone by NREL/DOE Univ. of West Virginia which is also
incorporated herein the record. CARB has not and does not plan to
study what happens over time to natural gas vehicles.neither is
CEC, Fed EPA DOE etc. and there is proposed legislation in Congress
to convert the nations truck . and bus fleet to natural gas
witho9ut study9ing this. This needs to be done as soon as possible.
SCAQMD recently said the they were going to look at only 2 buses in
a study of 22 buses. The grams of ch4 emissions per mile for buses
was.3 used in the Feb 2009 LCFS for LNG &CNG fuels while the
Washington D.c. study cited 10 and 17 grams per mile of ch4 and a
report done last year for South Coast for trucks found from 45 to
100 gerams ch4/methnae per mile emitted. GHG must be measured and
consdereed in this proceeding completely without an end run or
further omissions !!! Dr. Duffy was sent this info over 1 year ago
and over 2 years ago info was  cited to Anal Prabu and John Courtis
without responce and more recently as well !!! Pickens has money
but his Plan needs to be evaluated alomng with the environmental
impoact on water of fracking and included in this supplement to the
scopinmg plan FED.

More comments will follwo before  5pm tomarrow.