Comment Log Display

Richard Corey
Executive Officer
California Air Resources Board
Sacramento, California 

Subject: Proposed First Update to the AB32 Scoping Plan and in-use
vehicle efficiency 

Dear Mr. Corey:

Thank you for the opportunity to provide comments on the Proposed
First Update to the Climate Change Scoping Plan (Proposed Update).
We suggest short revisions regarding two topics.  

The first topic is low rolling resistance (LRR) passenger vehicle
replacement tires. We appreciate CARB’s acknowledgement in the
Proposed Update of the near term greenhouse gas (GHG) benefits. We
estimate that the statewide benefits include a reduction of least
three  million metric tons CO2e annually and an Energy Solutions
study commissioned by the South Coast AQMD shows avoided fuel cost
benefits many times greater than costs. 

We recommend several short revisions to the Proposed Update
regarding this topic, starting with adding a potential
implementation strategy based on text in the Transportation Working
Paper (p.24) (shown underlined in the attached PDF comment letter):


p. 54: “Furthermore, commercially available technologies, such as
low-rolling resistant tires for light-duty vehicles, can be
utilized by both new and in-use vehicles in the near-term to
achieve GHG emission reductions. In the short-term, improvements
can be made to the efficiency of in-use vehicles including
deployment of fuel efficient passenger vehicle replacement tires.
Deployment could include limited incentives, followed by ratings
and then standard setting to permanently shift the market.”

Next, we recommend adding an action item to the “Key Recommended
Actions for a Transportation System” Table (shown underlined in the
attached PDF comment letter): 

p.64: “CARB will assess potential in-use vehicle efficiency
opportunities including passenger vehicle replacement tires.”
We also recommend, as noted in the attachment to our letter,
clarifying that the original scoping plan included fuel efficient
tires as part of Measure T-4.

Second, we recommend clarifying the plug-in electric vehicle
off-peak charging recommendation in the table on page 64 to
explicitly address renewables(shown underlined in the attached PDF
comment letter): “…plug-in vehicle charging rates that strongly
encourage off-peak charging and managed charging to facilitate
renewable energy uptake…”.  

We 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

Note: please see PDF for this comment submittal for full letter
including test shown with underline and attachment to the letter