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Comment 1 for Auction Proceeds Funding Guidelines (ggrf-guidelines-ws) - 1st Workshop.


First Name: David
Last Name: Schonbrunn
Email Address: David@Schonbrunn.org
Affiliation: TRANSDEF

Subject: Life-Cycle Analysis
Comment:
TRANSDEF's only concern with these Guidelines is its silence on the
scope of required quantification. The Guidelines need to contain a
strong statement that the quantification procedure must include the
emissions for the full life-cycle of the proposed project or
program. 

It is only by measuring the full life-cycle emissions that it will
be possible to determine the proposed project's or program's net
contribution to global climate change.  

We believe this request to be consistent with existing ARB
practice. The requirement needs to be explicitly stated.

Thank you,

--David Schonbrunn.
President, TRANSDEF

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Date and Time Comment Was Submitted: 2015-06-21 18:23:04



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