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Comment 45 for Low Carbon Fuel Standard - Lifecycle Analysis (lcfs-lifecycle-ws) - 7th Workshop.
First Name: Mark
Last Name: Albers
Email Address: Mark.J.Albers@gmail.com
Affiliation:
Subject: Please Avoid Fuel Biases
Comment:
I am writing to comment on the Low Carbon Fuel Standard (LCFS) program. The State of California's LCFS will be a model for the rest of the United States, so it is especially important that the LCFS accurately and fairly assess all of the emissions associated with each fuel and its use. Each of the following elements is essential to ensure that the LCFS is not biased toward or against a particular fuel, and to make sure that you consider all of the associated emissions. I request that these be included in the final drafting of the Standard: 1 Upstream emissions: Emissions from the production of fuels are a critical component of evaluating carbon emission standards to ensure a comprehensive "well to wheels" assessment. 2 Drive train efficiency: Calculation of the carbon metric must include the drive train efficiency for each fuel type to fully estimate carbon emissions. I support the concept of a LCFS. However, I urge you to provide an impartial analysis of, and impartial standards for, energy and fuel alternatives by incorporating the elements described above. Sincerely, Mark J. Albers
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Date and Time Comment Was Submitted: 2009-02-13 18:53:41
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