Comment Log Display

I am writing to comment on the Low Carbon Fuel Standard (LCFS)
program.  The State of California's LCFS will be a model for the
rest of the United States, so it is especially important that the
LCFS accurately and fairly assess all of the emissions associated
with each fuel and its use. 

Each of the following elements is essential to ensure that the
LCFS is not biased toward or against a particular fuel, and to make
sure that you consider all of the associated emissions. I request
that these be included in the final drafting of the Standard:

1 Upstream emissions: Emissions from the production of fuels are a
critical component of evaluating carbon emission standards to
ensure a comprehensive "well to wheels" assessment.

2  Drive train efficiency:  Calculation of the carbon metric must
include the drive train efficiency for each fuel type to fully
estimate carbon emissions.

I support the concept of a LCFS.  However, I urge you to provide
an impartial analysis of, and impartial standards for, energy and
fuel alternatives by incorporating the elements described above.

Sincerely,
Mark J. Albers