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Comment 20 for Low Carbon Fuel Standard (lcfs09) - 15-1.

First NameKirk
Last NameCobb
Email Addresskcobb@superiorpt.com
AffiliationSuperior Process Technologies
SubjectComments and Recommendations for the CARB "UCO to Biodiesel" Model
Comment
Anil Prabhu
California Air Resources Board
Mr. Prabhu,

Attached are my comments and suggestions for the CARB GREET model
for the “UCO (used cooking oil) to Biodiesel” document.  

Several of us in this engineering office have independently
reviewed the CARB UCO-BD document, and have different perspectives
on suggested changes.  We hope you find our comments useful and
constructive.  They may be somewhat critical, but are all offered
honestly and in good faith.  Our goal in offering these criticisms
and suggestions is to strengthen your document, so that it can be
ultimately received as an authoritative reference document, and
highly regarded within the industry.

Two key suggestions that I am offering refer to:

1)     adding “energy ratios” to the CARB document, and 
2)     avoiding the use of CARB “default” values as a basis for
your calculations, but instead use recognized industry standard
references as a basis for your estimates and calculations.  

These two suggestions are described in more detail in the attached
document.  

I firmly believe that my suggestions will help to improve the CARB
“UCO to BD” document.
 
If you have any questions or thoughts, or wish to have further
discussion, please feel free to call me any time.        

Sincerely,

Kirk T. Cobb
Process Design Engineer
Superior Process Technologies
2520 Broadway St, NE 
Gleeson Place Suite # 200
Minneapolis, Minnesota 55413
kcobb@superiorpt.com
612-378-4770


Attachment www.arb.ca.gov/lists/lcfs09/427-ghg_-_uco_carb_model_comments_and_recommendations.doc
Original File NameGHG - UCO CARB Model Comments and Recommendations.doc
Date and Time Comment Was Submitted 2009-08-19 14:16:34

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