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Comment 80 for 2022 Scoping Plan Update - Scenario Inputs Technical Workshop (sp22-inputs-ws) - 1st Workshop.
First Name: Jack
Last Name: Fleck
Email Address: jack@350BayArea.org
Affiliation: 350 Bay Area
Subject: Comments/questions on Scoping Plan/Mobile Source Strategy
Comment:
Dear CARB, The questions below are intended to show that the 2020 Mobile Source Strategy will not be able to achieve California's SB 32 requirement of 40% GHG reduction by 2030. The more aggressive assumptions of Alternative 1 in the Proposed PATHWAYS Scenario Modeling Assumptions--in particular phasing out the sale of ICEVs by 2030 or sooner--are required to comply with SB 32. As you know, transportation is responsible for about half of GHG emissions in California. The Scoping Plan relies on CARB's Mobile Source Strategy to achieve the required emission reductions from the Transportation sector. I have three questions for CARB to address in the Mobile Source Strategy, which make it seem unlikely that the Scoping Plan can achieve California's goal of 40% GHG reduction by 2030. They pertain to Figure 13 in the MSS. (1) Figure 13 shows a decrease in GHGs/mile for ICE vehicles from about 255 to 210 g/mi (estimated and rounded). This is an improvement of 18% [=(255-210)/255]. How do you propose to achieve this reduction? I see footnote 91 on page 85, which links to Vision Scenario Planning, which has a link to passenger vehicles. But this link is broken, so I am unable to see how this 18% was achieved. However, the calculation below suggests that the 18% is overstated. Page 93 states that there will be a 2% improvement in fuel efficiency for new vehicles after 2026. Even if that occurred every year from 2021 - 2030, that would mean that new cars would have 22% better fuel efficiency by 2030. This means that the average new car over that 10 year period would have 11% better fuel efficiency. Assuming a 15 year car life, ⅓ of the cars would still be at the 2020 level of fuel efficiency. Therefore, the improvement from fuel efficiency would only be for ⅔ of the new vehicles x 11% = 7% improvement. In fact, that 7% improvement would actually be closer to the 5% range if the efficiency improvement is from 2026-2030 as stated on pg. 93. If there are also some improvements in the carbon intensity or increases in the percentage of ethanol for most cars, or likewise for biofuels for the small number of light duty vehicles which are diesel, that could lower the grams per mile by another 2% or so. This estimated reduction is low since the MSS does not anticipate major changes in the amount of ethanol in California's fuel. This estimated reduction is only 9%, so I don't see how Figure 13 can be predicting 18% improvement in GHGs per mile for ICE vehicles. Could you please explain? (2) I'm also trying to reconcile Figure 13 with Figures 15 & 17 in the MSS. I'm estimating that Figure 17 shows a reduction of GHGs from light duty vehicles of about 41%--[110-65)/110). Figure 15 shows 24 million vehicles in 2020 and 28 million in 2030, including 6 million BEVs and 2 million PHEVs. Figure 13 suggests a different result than Figure 17, i.e. 23% reduction of GHGs from LDVs, as calculated below: 2020 total emissions: (assuming 13,000 miles per vehicle--source FHWA--341 billion VMT in California / DMV 26 million vehicles in CA = 13,115 miles) 23.3 million ICE vehicles x 13,000 miles per vehicle x 255 g/mi = 77 million metric tons (MMT), plus about 1 MMT from EVs and BEVs for a total of 78 MMT. (note that 78 MMT is well below the actual emissions from LDVs since the 255 g/mi understates actual emissions; but this does not affect the overall calculation here) 2030 total emissions: 6 million BEVs x 40 g/mi x 13,000 miles per veh = 3.1 MMT 2 million PHEVs x 90 g/mi x 13,000 miles per veh = 2.3 MMT 20 million ICEVs x 210 g/mi x 13,000 miles per veh = 54.6 MMT Total = 60 MMT Calculated reduction = (78 - 60/78) = 23% We can adjust this for projected VMT reductions. The MSS assumes 15% total (not per capita) VMT reduction by 2050. Assuming straight line reduction, this would be 5% reduction by 2030. Using CARB's number of vehicles--24 million x 13,000 miles = 312 billion vehicle miles. A 5% reduction would result in 296 billion vehicle miles. For 2030, with 28 million cars on the road this would mean reducing the miles traveled per light duty vehicle to 296/28 = 10,600 miles, i.e., a reduction of (13,000 - 10,600/13,000) = 18% per vehicle. This VMT adjustment gives: 2030 total emissions: 6 million BEVs x 40 g/mi x 10,600 miles/veh = 2.5 MMT 2 million PHEVs x 90 g/mi x 10,600 miles/veh = 1.9 MMT 20 million ICEVs x 210 g/mi x 10,600 miles/veh = 44.5 MMT Total 48.9 MMT Calculated reduction with 18% VMT reduction (5% reduction from 2020 level) = (78 - 48.9)/78 = 37% I.e. Figure 13, even when adjusted for very aggressive VMT reductions, suggests 37% GHG reduction, not 41% as shown in Figure 17. Arguably this discrepancy could be significantly greater than 4%, given the magnitude of predicted VMT reductions. (3) As noted in question 2, the MSS is suggesting that very substantial VMT reductions will take place in spite of a substantial increase in the number of vehicles from 24 to 28 million vehicles. How does the MSS reconcile the reduction of VMT with the increase in vehicles? To reiterate my questions: 1. How do you propose to achieve 18% improvement in fuel efficiency for ICE vehicles by 2030? 2. How do you propose to achieve 41% GHG reduction from light duty vehicles? Assuming 8 million EVs and 5% VMT reduction--this appears to result in 36% GHG reduction using Figure 13. 3. How does CARB propose to achieve VMT reductions of 18%, given the growth in vehicles from 24 million to 28 million? Thank you for your important work on the Scoping Plan and Mobile Source Strategy! Sincerely, Jack Lucero Fleck PE, 350 Bay Area Transportation team
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Date and Time Comment Was Submitted: 2021-10-22 19:39:06
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