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Comment 49 for Transportation Comments for the GHG Scoping Plan (sp-transport-ws) - 1st Workshop.


First Name: Keith
Last Name: Adams
Email Address: adamskb@airproducts.com
Affiliation: Air Products and Chemicals

Subject: Comments on Low Carbon Fuel Standard
Comment:
Air Products encourages CARB to consider facility-specific process
efficiency in determining the CO2 intensity of the fuels produced.
 Use of generic emission factors for refinery process inputs
reduces the incentive for those refiners who implement the most
comprehensive energy and process efficiency improvements. 
Encouraging such efficiency improvements is consistent with CARB’s
climate change and air quality objectives, and should be supported
through all the emission reduction measures considered.

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Date and Time Comment Was Submitted: 2008-08-01 16:00:13



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