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Thank you for the opportunity to comment on the Proposed Scoping
Plan.  I have analyzed CARB’s GHG calculations for high-speed rail
and have found that CARB’s estimate understates the impact of
high-speed rail on GHG emissions.  I estimate that high-speed rail
will reduce CO2E by 2.5 MMT in 2020, more than twice CARB’s
estimate of 1.1 MMT CO2E.

Two factors drive most of the difference between CARB’s estimate
and mine:
* CARB’s ridership estimate is based on a gasoline price in 2020
of $2.74 per gallon.  If the price of gasoline is closer to $4 per
gallon in 2020, more travelers will choose high-speed rail over air
or auto travel, reducing CO2E by an additional 0.8 MMT in 2020.
* CARB’s carbon factor for air travel is lower than most analysts
use.  Changing the parameter for air travel generates a further cut
in emissions of 0.5 MMT CO2E.  

Details of the analysis are included in the attached report.

-Carolyn Sherwood Call, Ph.D.