First Name | DON |
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Last Name | ZWEIFEL |
Email Address | dzweifel@sbcglobal.net |
Affiliation | SOUTHERN CALIFORNIA BIOFUEL/SCB |
Subject | RE: MITIGATING FACTORS IMPACTING IMPLEMENTATION |
Comment | To whom it may concern: Be it hereby understood that whereas ARB has unfortunately failed to factor into the equation positive ramifications of current and future BD or Biodiesel utilization should have had on their extrapolations. SCB therefore concludes it is indicative of a insufficiency of evidence to adequately ascertain future projections of PM 2.5 and greater-diameter particulate emissions. SCB therefore formally requests that using BD in various blends, i.e., B2, B5, B20 and B100 be inculcated into ARB's projected assessments regarding compliance with new regulatory mandates as to mitigation of risks to human health, i.e., PM 2.5 and larger-sized particulates. It is therefore our considered deduction that if B20 for example is mandated for all off-road construction equipment, ARB will as a consequence discover a significant reduction in PM 2.5 statewide as a starter. We also contend that last year's Ultra-Low Sulfur Diesel or ULSD implementation was most likely not calculated in ARB's previous future projections in regards to PM 2.5 emissions. It is therefore our formal allegation that it is incumbent upon ARB to substantiate claims by their deputy executive director/DED, i.e., "Oh yes, we certainly included ULSD in our extrapolations..." according to the DED at ARB's hearing at Marriott Del Mar on Fri., 25 May, 2007. Thanking you in advance for your consideration in this matter |
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Date and Time Comment Was Submitted | 2007-07-10 19:40:27 |
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