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Comment #12 for LCFS Program Review Advisory Panel (2011)
(lcfsadvisorypanel-ws) - 4th Workshop

First Name: Greg
Last Name: Karras
Email Address: gkatcbe@gmail.com
Affiliation
SubjectRequest for Advisory Panel recommendation on petroleum fuels carbon intensity values
Comment
Dear Advisory Panel members, 

Accurate carbon intensity estimates for transportation fuels are
critical to the efficacy of the LCFS. Refined petroleum fuels now
dominate the transport fuel mix.  However, current LCFS carbon
intensity values for these fuels omit direct and indirect emissions
associated with refining denser, higher sulfur crude oils.  Please
consider the attached scientific evidence quantifying the impact of
these emissions that are likely to increase dramatically by 2020 on
the efficacy of the LCFS and supporting an Advisory Panel
recommendation for revisions to account for this source of
emissions in the carbon intensity values.  Attachments noted in
this comment will follow directly.  Thank you, in advance for
considering this critically important matter.  Greg Karras, Senior
Scientist, CBE
Attachment www.arb.ca.gov/lists/lcfsadvisorypanel-ws/23-cbe-arb_adv_panel_102411.pdf

Original File Name: CBE-ARB Adv Panel 102411.pdf

Date and Time Comment Was Submitted: 2011-10-24 22:11:51


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