Comment Log Display

The City of Inglewood California and the CBA urges the ARB to adopt
the LCFS.  

Implementation Timeline.
•	We agree with concerns voiced by other groups such as the Union
of Concerned Scientists that much more needs to be done to reduce
GHG/carbon emissions in the early years of LCFS - a unit of
carbon/GHG reduction today is worth more than a comparable
reduction in the future.  
•	Revise the implementation timeline for the diesel fuel pool to
include more aggressive decreases in carbon intensity beginning in
2010.
•	1% reduction could be achieved with 31 to 35 mgpy of California
produced biodiesel made from waste feedstocks such as animal fats
and used cooking oils (the latter is based on an LCFS pathway for
biodiesel produced in California using inedible animal fats and
used cooking oils achieving a 70% and 80% reduction respectively in
carbon intensity versus the current petroleum diesel baseline of
94.71 gCO2e/MJ).
•	California has nine biodiesel plants either currently operating
or engaged in commissioning with a combined production capacity of
approximately 63 million gallons per year; another 4 plants are
idle and at least one other is under construction. Thus,
California’s 2009 biodiesel production capacity is more than
capable of meeting the demands of a 1% reduction in carbon
intensity beginning January 2010.  

Fuel Pathways
CBA urges ARB to develop and publish LCFS fuel pathways for
biodiesel produced in California and for biodiesel using waste
feedstocks such as used cooking oil and inedible animal fats.


Rick Longbart
City of Inglewood