Comment Log Display

There are some critical issues the State of California must address
before going down the ACF road as proposed.

It is baffling, if not stunning, why renewable diesel was not
presented as an ACF option for diesel vehicles.  ARB says the
primary driver for the ACF regulation is to reduce greenhouse gas
emissions and, for that reason, is mandating diesel vehicles be
replaced with ZEVs.  ZEV means grid power and right now ~40% of the
grid power comes from natural gas fired power plants, and that
fraction goes way up when demand it at its highest.  But renewable
diesel is by definition 100% carbon neutral.  If the objective is
to reduced greenhouse gases as fast as possible why on earth
exclude renewable diesel as an option to ZEVs?

Moreover, putting all your energy supply eggs in one basket (grid
power) is a strategic folly.  The grid goes down and then what?  No
transportation system?  Allowing renewable diesel diversifies the
transportation system making it more robust and less vulnerable to
disruption.

I realize ARB has secondary reasons for pushing this regulation: 
reducing ambient PM 2.5 and ozone.  This seems like a stretch.  ARB
is attacking these two with a slew of other regulations, including
amendments to the mobile Off-Road Regulation and the recently
adopted, yet to be enforced Heavy-Duty Vehicle inspection and
maintenance program, to name a few.

But even assuming PM reductions are essential to this regulation
(they are not) PM emissions from diesel engines are lower than PM
emissions from gas fired power plants.  ARB/EPA emission
certification tests for diesel engines show either extremely low
(0.002 grams/kWhr) or undetectable PM emissions.   Compare that
with emissions from natural gas fired power plants at 0.017
grams/kWhr (Argonne National Labs, ANL-20/41, August 2020).  

Finally, ARB saying the ACF will reduce NOx and hence ozone.  This
one is odd because no areas of the state rely on this regulation to
meet federal ambient ozone standards.  That is, these regions have
approved air quality improvement plans to meet federal standards
that do include nor rely on the ACF.  

So, to sum up. If the goal really is first and foremost to reduce
greenhouse gas emissions as fast as possible while supporting a
robust transportation system, and while not compromising other air
quality goals, it seems like common sense to include renewable
diesel as a compliance option for diesel vehicles.

For the record I have no vested interest in renewable diesel.

Regards,
Larry Rennacker
ArrowTek