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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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