Comment Log Display

Please note - we have attached our comments as a PDF and also
included the text of these comments here.

August 2, 2013

Mike Tollstrup
Chief, Project Assessment Branch 
1001 I Street
California Air Resources Board
Sacramento, California 95814

Subject: AB32 Scoping Plan Update – Passenger Vehicle In-Use
Efficiency

Dear Mr. Tollstrup:

Thank you for the opportunity to provide suggestions for the AB32
Scoping Plan update. We encourage you to build on California’s
leadership reducing transportation emissions by including passenger
vehicle in-use efficiency in the scoping plan update.

In particular, we recommend that the update include a pathway to
improve deployment of fuel efficient passenger vehicle replacement
tire and engine oil technology. The scoping plan update should
include programs starting with tire incentives for a limited time
period and ratings followed by standards to permanently shift the
market. These programs would allow drivers of every income level to
participate directly in the benefits of AB32. We also encourage
evaluation of potential measures for improved engine oil
technology. 

The original scoping plan (measure T-4) set goals of over three
million metric tons per year of GHG savings and $750 million in
annual consumer savings from these technologies. These goals are
achievable with a very high benefit/cost ratio and can leverage CEC
research on low rolling resistance tires as well as precedents in
Europe, Japan and South Korea.

We have attached suggested language for the scoping plan update and
appreciate your consideration of our comments. Please contact me or
have your staff contact me at epike@energy-solution.com or (510)
482-4420 x239 if you have any questions.

Sincerely,
 
Ed Pike, P.E.
Senior Project Manager 
-------------------------------------------------------

Attachment: Suggested language for scoping plan update

"Passenger Vehicle Efficiency Measures Update

Several passenger vehicle in-use efficiency measures would
complement adopted AB32 policies for new vehicles, fuels and
vehicle miles traveled. Two opportunities identified in the
original scoping plan include low rolling resistance replacement
tires and low viscosity engine oil. Implementing these measures
will build on the adopted tire inflation early action measure and
result in additional emission reductions of greater than 3 million
metric tons per year and consumer cost savings of greater than $750
million per year. These programs would be an opportunity for
drivers of every income level, including low income drivers, to
participate directly in the fuel cost savings and other benefits of
AB32.

Tires
Low rolling resistance replacement tire technology can reduce
long-term GHG and fuel consumption by 4 percent or greater. This
technology is expected to continue to advance for new vehicles due
to California/federal GHG and fuel economy standards and vehicle
labeling but no programs are in place for the replacement tire
market. (Low rolling resistance tires are required for heavy duty
vehicles under California’s Smartway regulation.) 

A two-phased California approach is recommended to maximize the
benefits of low rolling resistance replacement tires for passenger
vehicles. First, a consumer incentive and education pilot program
could be implemented on a regional basis, and potentially expanded
state-wide (assuming that funding is available) to create consumer
pull for the most energy efficient replacement tires. This program
should be followed by the adoption of standards, leveraging
existing CEC research, to permanently shift the market. California
can also leverage experience from tire programs developed in the
European Union, Japan and South Korea to develop programs and avoid
the risk that low-quality replacement tires pushed out of
international markets could be shifted to California.  

Low Friction Engine Oils
Engine oil formulations can also impact a vehicle’s GHG emissions
because reducing friction from the internal engine parts will
improve the overall efficiently of the engine. This, in turn,
reduces the engine load and fuel consumption. Use of low friction
engine oils in passenger vehicles can result in up to 2 percent GHG
reduction. Initial efforts could focus on a consumer incentive and
education pilot program, potentially followed by implementation of
a broader program and/or regulation.