Comment Log Display
Below is the comment you selected to display.
Comment 8 for LCFS Program Review Advisory Panel (2011) (lcfsadvisorypanel-ws) - 4th Workshop.
First Name: Harvey
Last Name: EDER
Email Address: harveyederpspc@yahoo.com
Affiliation: self & PSPC PUBLIC SOLAR POWER COALITION
Subject: Oct 21 timely comments on LCA /LCFS CARB Pt.2 if 3 plus by Harvey Eder &PSPC to 45 Day Do.
Comment:
This is a part 2 of 3 or more submittals on LCFS CARB testimeny onthe record ion OCt 21,2011 to be included rather that ignored as in the past in the record for staff Expert Work Group and Sustainiability Work Group to be cirulated for comments in the 45 day public somment document due Oct 31 to go to CARB BD in mid Dec 2011 to make law by Jan 1.2011. This all is submitted under protest with possible litigation considered as part of the record. Most comments will flow but this was ignored by CARB staff like Richard, who cut me off during public comments in the Aug or Sept meeting of the Expert Wk Group violating the brown act etc. This was rudely done as if I/WE worked for him rather than him being a public servant and work ing for us !!! Maybe most people in the room worked for his but this violated due process and didn't let this infor. before the Panel /Group this is also being submitted to the Extert wk Grroup and to the Sustainablity Work Group for LCFS for their record they were cited in Ch 2 and 5 in Oct 19,2001 Weed circulation on Harmony with other programs and Life Cycle Analysis. This is not enough time to respond ! Also we had been notified we had untilMonday Oct 24 in writting to respond to this. Attached is a copy of emails (everything said orally via email and over the telephone in this matter are on the record) It is address to Henry Hogo Asst. Ex Officer for SCD and contains a copy of an email to John Courtis regarding looking at Natural Gas emissions over time the life of a vehicle and corredtions to the CARB Staff document GREET ?GTAP LCFS LCA of CI done by Staff andHowdy Henry Hogo, It's been a while since we last talked. I hope you are well. Sorry it has taken me so long to get back to you. Here is an email send to CARB LCFS group manager John Courtis last month in reference to what we talked about methane emissions in the real world over time/the life of the vehicle. I've talked with John Courtis and his staff ( Kevin Cleary) a few times and am shaking out their numbers which are dubious. I will send you another email with further communications. Please send me any informations that you have that we talked about. I will call you. Thanks, take care Harvey Eder (310)3932589 RUDE ! NG VEH. HE/PSPC 3/9/11 From: Harvey EderView Contact To: jcourtis@arb.ca.gov Cc: harveyederpspc@yahoo.com -------------------------------------------------------------------------------- Howdy John Courtis, It's been a month or more since I emailed you and your staff and called you on the phone, to no avail. Sir this is more than rude. It follows the pattern that you and your staff have exibited going back 3 years ago when I/We contacted you with testimony / information for the record in LCFS for the Scoping Plan ! Once again in reference to the paper circulated for LCFS for LNG ("The Staff of the Air Resources Board developed this preliminary draft version as part of the Low Carbon Fuel Standard regululatory prosess The ARB acknowledges contributions from Life Cycle Associates ( under contract with the California Energy Commision) during development of this docyument") ( CNG etc.) please send me at once the correct link for the CH4 and N2O 2.5 gCO2e/MJ that connects with the Austrailian study from apx. 10 years ago that forms the basis of CARB numbers for these GHG emissions. Page 17 of the LCFS Tank To Wheel or what you used LNG Tailpipe emissions. Again the information you are using is dated and the study done by NREL showing CH4 emissions over the life of an engine ( 3 years ) shows 70% increase in CH4 emissions from comparing 2001 NG buses in DC with 2004 NG buses. This omitts N2O which has the number of 300 times co2 e and increases the Washing DC study numbers 10%.. Your document refers to a web site that doesn't work now http://www.arb.ca.gov/fuels/lcfs/lcfs.htm "for complete details" " Preliminary Draft Distrubuted For Public Comment. The study that disproves CARBs LCFS numbers is http://www.nrel.gov/docs/fy06osti/36355.pdf this document paper is Emission Testing of Washington Metropolitan Area Transit Authority (WMATA) Natural Gas and Diesel Transit Buses Nrel, W.V. University , U.S. DOE. Page 22 shows graphs Fig.14 of Methane Emissions (CNG vehicles only) which is multiplied by 21 times for CH4 at least NASAs James Hansen uses 33 times as well as fig. 15 co2 emissions., Page 16 and 17 show NG CH4 and CO2 emissions for 2001 (3 yrs old buses) and 2004 new NG buses. There is an average of 17.3 g/mi CH4 at 42,886 BTU/mile and 10.6 CH4 g/mi and 2,173 CO2 g/mi at 40,899 BTU/mi. This shown 2004 buses CH4 emissions only yield 5.128 g co2e and 2001 (3 year old buses yeild 8.03 g co2 e per mj )or more than 2 to 3 times your numbers without counting N2O( degradation of the engine ocver the life of the vehicle) and with a linariar increaes of this rate of emissions of an average of 16.73 g CO2e per MJ to with an exponential increase at the Nrel WV University , DOE of 43.54 g CO2 e of CH4 over an 18 year life of the vehicle, or from apx. 6+ times the amount linarly aging engines to over 17.4 times or a magnatude and more of increases the dated numbers CARB and your staff used with counting N2O. Please Respond at once this time... Thanks, take care Harvey Eder Ex. Director PSPC Public Solar Power Coalition 1218 12 th St. #25 Santa Monica, Ca. 90401 (310)3932589 PS the emphasis that CARB and SCD is putting on converting to Natural Gas Vehicles rather that Solar Electric etc. is beyond illadvised almost criminal. 0UR SERVICES ARE AVAILABLE FOR CONSULTING IN THIS REGARD. CC will be sent to Dr. Michael Benjamin and Dr. Cody Livingston CARB Staff that introduced us to this study on DC NG Buses. Howdy Aaron, Here is info about the NREL study on natural gas GHG emissions over the life of a vehicle that I told you about. Hope this get to you. Thanks, take care Harvey (310)3932589 brought to staffs attention over the past several years. Please excuse the mistakes in this document in spelling, grammer etc. There is only limited (not legal time to respond.S Cal busses are taken after 12 years and sold to Mexico etc. and these emissions are all part of the life cycle emissions etc.
Attachment:
Original File Name:
Date and Time Comment Was Submitted: 2011-10-21 13:14:58
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.