Comment Log Display

Earl Withycombe, P.E. 
South Coast AQMD Planning Liaison 
Planning & Technical Support Division 
California Air Resources Board

Earl,

From your just-released staff report,
http://arb.ca.gov/cc/sb375/staffreport_sb375080910.pdf, on Page 22
,comes the following very confusing 2-sentence paragraph:
 
"Using the data provided by the MPOs over the past four months,
the
proposed targets would result in a reduction of greenhouse gas
emissions of over three million metric tons of CO2 per year
(MMTCO2/year) in 2020, and 15 MMTCO2/year in 2035. When these
reductions are applied to the most recent statewide 2020 emissions
forecast, the emissions target for passenger vehicles in
California’s 2008 Climate Change Scoping Plan is met."

I assume your first sentence is true. However, the second sentence
is false, for the 2035 value. This paragraph mixes in the 2035
reductions of 15 MMTC02/year where it does not belong. The 2008
Scoping Plan is quantitatively ONLY about AB32. AB32 only goes out
to 2020. The 2008 Scoping Plan does NOT support the 15 MMTC02
value
for 2035. 

Nothing does.

So I have these 4 questions. What about 2035? What about the
Governor's Executive Order?  What about climate stability?

My calculations indicate that a much larger reduction is required
by 2035, as follows.

(Please tell me what is wrong with this calculation. For Pavely
and
the Governor's Executive Order trajectories, I use Figure 1 of
http://www.nrdc.org/globalwarming/sb375/files/sb375.pdf.)

1.) Just to show how far off CARB targets are, for 2035, I will
use
a "huge"  20% reduction, to result in a 2005 to 2035 factor of .8.

2.) I will use the SANDAG populations figures, which is a growth
of
from 3034388 to 3984753, for a factor of (the larger over the
smaller) 1.313.

3.) Using the values from the above-mentioned Figure 1, the Pavley
reduction, extrapolated out to 2035, give a very nice reduction
factor of .685.

4.) The LCFS factor is .9.

5.) Using the values from the above-mentioned Figure 1, the
straight-line trajectory of the reduction needed to get and 80%
reduction by 2050 is .525.

The four factors are multiplied to give (.8)(1.313)(.685)(.90) =
.648. This is not good enough. We need this to be at least as low
as .525.

A reduction of 35.1% will do the trick: (.649)(1.313)(.685)(.9) =
.525

Please let me know what is wrong with these calculations. If they
are correct, the ARB Directors must not approve your 2035
reductions. They are way too small.


Regards,

 
Mike Bullock
1800 Bayberry Drive
Oceanside, Ca 92054
760-754-8025
Retired Satellite Systems Engineer, 36 years
Co-author, "A Plan to Efficiently and Conveniently Unbundle Car
Parking Cost"