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Comment 36 for Low Carbon Fuel Standard - Lifecycle Analysis (lcfs-lifecycle-ws) - 6th Workshop.
First Name: Stewart
Last Name: Bailey
Email Address: stewartbailey@sasolchevron.com
Affiliation: Sasol Chevron
Subject: Gas to Liquids: importance of full co-product accounting for Life Cycle Analysis
Comment:
The attached report highlights the importance of fair and comprehensive accounting for Gas to Liquid (GTL)co-products re: the GTL pathway for the Low Carbon Fuel Standard. If the full GHG benefits of all GTL co-products are considered from an industry perspective, GHG emissions from GTL are lower than conventional diesel fuel. In particular, there is new important and impactful data in the attached report that highlights the benefits of GTL base oils. Our latest report is scientifically defensible and was developed in order to ensure that GTL is correctly and comprehensively evaluated as the LCFS process unfolds. To this end, we respectfully request that CARB accepts our submission and our proposal. Thank you for your consideration. Stewart Bailey and Grant Forman Sasol Chevron
Attachment: www.arb.ca.gov/lists/lcfs-lifecycle-ws/57-full_carb_the_greenhouse_gas_impact_of_gtl_dec_08.pdf
Original File Name: FULL_CARB_The Greenhouse_Gas_Impact_of_GTL_Dec_08.pdf
Date and Time Comment Was Submitted: 2008-12-15 09:07:54
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