Comment Log Display

Comment Log Display

Below is the comment you selected to display.
Comment 53 for Low Carbon Fuel Standard - Policy and Regulatory Development (lcfs-policy-ws) - 5th Workshop.


First Name: Garrett
Last Name: Stone
Email Address: garrett.stone@aspirecorp.net
Affiliation: ASPIRE CORP

Subject: Comments to the Draft Regulation and Supporting Document presented Oct 16 2008
Comment:
Comments are with reference to the Draft Regulation posted here:
http://www.arb.ca.gov/fuels/lcfs/101008lcfsreg_draft.pdf

And to the Supporting Document posted here:
http://www.arb.ca.gov/fuels/lcfs/101608lcfs_supdoc.pdf

FIRST COMMENT
With reference to Draft Regulation Table 2, page 4

We recommend that Table 2 LCFS Compliance Schedule for Diesel
Fuel, (and Table 1 on page 3 for Gasoline Fuel) be modified to
require a smooth decrease in fuel Carbon Intensity.

We believe that the ANNUAL INCREASE in the amount of DECREASE in
fuel Carbon Intensity on a fleet-wide basis is more likely to be a
smooth curve rather than one that first jumps up and then back down
three separate times (2011 to 2012, 2016 to 2017, and 2019 to 2020)
as does the Compliance Schedule presented in Table 2. This point is
especially clear when the proposed amount of ANNUAL INCREASE as
shown in the Compliance Schedule is presented in chart form such as
the one below.

TABLE 2 - ANNUAL INCREASE IN % REDUCTION IN CARBON INTENSITY
2.0                                            X    X
1.9
1.8
1.7                                  X
1.6
1.5                                       X
1.4
1.3
1.2
1.1
1.0                             X
0.9
0.8
0.7
0.6
0.5                        X                             X
0.4
0.3         X         X
0.2              X
0.1
0.0    X
YEAR 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

No doubt it is good policy to start with small annual reductions
as low carbon fuels are introduced and then increase the size of
the annual reductions as low carbon fuels gain wider use. However,
unless there is a policy driven reason to require only a tiny
annual reduction of 0.5% in the “final year” of 2020, it seems to
be a better fit with the natural world to start with small
reductions and steadily increase the size of the annual reduction.
After all, each annual reduction is a  “per cent of the baseline
CO2 emission” so there is no “per cent of a per cent” issue here.
And, steadily increasing the annual reduction makes sense. As low
carbon fuels gain market share you would expect that a 2.0%
reduction in 2020 would become as easy to make as a 0.2% reduction
in 2011. With growing use of low carbon fuel, it seems unlikely
that any later year would have a smaller reduction than an earlier
year. It is also unlikely that the reduction curve would reach a
“flat top” (see 2018 and 2019 in the chart) in any year prior to
the “final year”. In fact, given steadily increasing use of low
carbon fuels, it seems most likely that the largest annual
reduction would occur in the “final year”. Especially since 2020 is
not really “a final year” at all, just a milestone on the way to
2050.

SECOND COMMENT

With reference to Table 3, page 12 of the Supporting Document:

LINE 3	Average Corn Ethanol	CI = 68.2	LUC = 35	Total CI = 103.2

Comment: The only apparent reference for Carbon Intensity of Corn
Ethanol on the CARB website is the one released 04/23/08:
http://www.arb.ca.gov/fuels/lcfs/042308lcfs_etoh.pdf.

The bottom line of the table on page 6 of the 04/23/08 document
specifies a TWW CI for denatured corn ethanol of 75.6 g/MJ (dry
mill) and 89.0 g/MJ (wet mill). A non-weighted average of those two
values is 82.3 g/MJ and the Total CI, using 35 g/MJ for LUC, would
be 117.3 g/MJ.

What is the source for the new 68.2 g/MJ value for CI? Can you
post the supporting calculation?



Attachment: www.arb.ca.gov/lists/lcfs-policy-ws/58-comments_in_response_to_the_draft_regulation_10-24-08.doc

Original File Name: Comments in Response to the Draft Regulation 10-24-08.doc

Date and Time Comment Was Submitted: 2008-11-14 16:01:20



If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.


Board Comments Home

preload