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Comment 8 for LCFS Program Review Advisory Panel (2011) (lcfsadvisorypanel-ws) - 4th Workshop.


First Name: Harvey
Last Name: EDER
Email Address: harveyederpspc@yahoo.com
Affiliation: self & PSPC PUBLIC SOLAR POWER COALITION

Subject: Oct 21 timely comments on LCA /LCFS CARB Pt.2 if 3 plus by Harvey Eder &PSPC to 45 Day Do.
Comment:
This is a part 2 of 3 or more submittals on LCFS CARB testimeny
onthe record ion OCt 21,2011 to be included rather that ignored as
in the past in the record for staff Expert Work Group and
Sustainiability Work Group to be cirulated for comments in the 45
day public somment document due Oct 31 to go to CARB BD in mid Dec
2011 to make law by Jan 1.2011. This  all is submitted under
protest with possible litigation considered as part of the record.
Most comments will flow but this was ignored by CARB staff like
Richard, who cut me off during public comments in the Aug or Sept
meeting of the Expert Wk Group violating the brown act 
etc. This was rudely done as if I/WE worked for him rather than 
him being a public servant and work ing for us !!! Maybe most
people in  the room worked for his but this violated due process
and didn't let this infor. before the Panel /Group this is also
being submitted to the Extert wk Grroup and to the Sustainablity
Work Group for LCFS  for their record they were cited in Ch 2 and 5
in Oct 19,2001 Weed circulation on Harmony with other programs and
Life Cycle Analysis. This is not enough time to respond ! Also we
had been notified we had untilMonday Oct 24 in writting to respond
to this.

Attached is a copy of emails  (everything said orally via email and
over the telephone in this matter are on the record)  It is address
to Henry Hogo Asst. Ex Officer for SCD and contains a copy of an
email to John Courtis regarding looking at Natural Gas emissions
over time the life of a vehicle and corredtions to the CARB Staff
document GREET ?GTAP LCFS LCA of CI done by Staff andHowdy Henry
Hogo,
 
     It's been a while since we last talked. I hope you are well.
Sorry it has taken me so long to get back to you. Here is an email
send to CARB LCFS group manager John Courtis last month in
reference to what we talked about methane emissions in the real
world over time/the life of the vehicle. I've talked with John
Courtis and his staff ( Kevin Cleary) a few times and am shaking
out their numbers which are dubious. I will send you another email
with further communications. Please send me any informations that
you have that we talked about. I will call you.
 
Thanks, take care
 
Harvey Eder (310)3932589
 
 
 
 
 
 
RUDE ! NG VEH. HE/PSPC 3/9/11
From: Harvey Eder   View Contact 
To: jcourtis@arb.ca.gov   
Cc: harveyederpspc@yahoo.com 


--------------------------------------------------------------------------------

Howdy John Courtis,
 
     It's been a month or more since I emailed you and your staff
and called you on the phone, to no avail. Sir this is more than
rude. It follows the pattern that you and your staff have exibited
going back 3 years ago when I/We contacted you with testimony /
information for the record in LCFS for the Scoping Plan !
     Once again in reference to the paper circulated for LCFS for
LNG ("The Staff of the Air Resources Board developed this
preliminary draft version as part of the Low Carbon Fuel Standard
regululatory prosess  The ARB acknowledges contributions from Life
Cycle Associates ( under contract with the California Energy
Commision) during development of this docyument") ( CNG etc.) 
please send me at once the correct link for the CH4 and N2O 2.5
gCO2e/MJ that connects with the Austrailian study from apx. 10
years ago that forms the basis of CARB numbers for these GHG
emissions. Page 17 of the LCFS  Tank To Wheel or what you used LNG
Tailpipe emissions. Again the information you are using is dated
and the study  done by NREL  showing CH4 emissions over the life of
an engine ( 3 years ) shows 70% increase in CH4 emissions from
comparing 2001 NG buses in DC with 2004 NG buses. This omitts N2O
which has the number of 300 times co2 e and increases the Washing
DC study numbers 10%.. Your document refers to a web site that
doesn't work now http://www.arb.ca.gov/fuels/lcfs/lcfs.htm "for
complete details" " Preliminary Draft Distrubuted For Public
Comment.
     The study that disproves CARBs LCFS numbers is
http://www.nrel.gov/docs/fy06osti/36355.pdf   this document paper
is Emission Testing of Washington Metropolitan Area Transit
Authority (WMATA) Natural Gas and Diesel Transit Buses Nrel, W.V.
University , U.S. DOE. Page 22 shows graphs Fig.14 of Methane
Emissions (CNG vehicles only)  which is multiplied by 21 times  for
CH4 at least NASAs James Hansen uses 33 times as well as fig. 15
co2 emissions., Page 16 and 17  show NG CH4  and CO2 emissions for
2001 (3 yrs old buses) and 2004 new NG buses. There is an average
of 17.3 g/mi CH4 at 42,886 BTU/mile and 10.6 CH4 g/mi  and 2,173
CO2 g/mi at 40,899 BTU/mi. This shown 2004 buses CH4 emissions only
yield 5.128 g co2e and 2001 (3 year old buses yeild 8.03 g co2 e
per mj )or more than 2 to 3 times your numbers without counting
N2O( degradation of the engine ocver the life of the vehicle) and
with a linariar increaes of this rate of emissions of an average of
16.73 g CO2e per MJ to with an exponential increase at the Nrel WV
University , DOE of 43.54 g CO2 e of CH4  over an 18 year life of
the vehicle, or from apx. 6+ times  the amount linarly aging
engines to  over 17.4 times or a magnatude and more of increases
the dated numbers CARB  and your staff used with counting N2O.
   Please Respond at once this time...
 
Thanks, take care
Harvey Eder Ex. Director PSPC Public Solar Power Coalition
1218 12 th St. #25
Santa Monica, Ca. 90401
(310)3932589
 
PS the emphasis that CARB and SCD is putting on converting to
Natural Gas Vehicles rather that Solar Electric etc. is beyond
illadvised almost criminal.
0UR SERVICES ARE AVAILABLE FOR CONSULTING IN THIS REGARD.
CC will be sent to Dr. Michael Benjamin and Dr. Cody Livingston
CARB Staff that introduced us to this study on DC NG Buses.




Howdy Aaron, 
 
     Here is info about the NREL study on natural gas GHG emissions
over the life of a vehicle that I told you about. Hope this get to
you.
 
Thanks, take care
 
Harvey (310)3932589

 brought to staffs attention over the past several years.

Please excuse the mistakes in this document in spelling, grammer
etc. There is only limited (not legal time to respond.S Cal busses
are taken after 12 years and sold to Mexico etc. and these
emissions are all part   of the life cycle emissions  etc.

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2011-10-21 13:14:58



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