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Comment 233 for In-Use Off-Road Diesel Fueled Engines (ordiesl07) - 45 Day.

First NameDON
Last NameZWEIFEL
Email Addressdzweifel@sbcglobal.net
AffiliationSOUTHERN CALIFORNIA BIOFUEL/SCB
SubjectRE: 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

Attachment
Original File Name
Date and Time Comment Was Submitted 2007-07-10 19:40:27

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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