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Comment 74 for Public Comments for LCFS pathway applications (tier2lcfspathways-ws) - 2nd Workshop.
First Name: Kevin
Last Name: Hamilton
Email Address: kevin.hamilton@centralcalasthma.org
Affiliation: CENTRAL CALIFORNIA ASTHMA COLLABORATIVE
Subject: LCFS pathway applications B01741-3 inclusive
Comment:
Central California Asthma Collaborative opposes approval of these three applications for three reason: 1) POET continues to utilize energy derived from coal fired powerplant generated steam. ARB should no longer accept these CI "adjustments" that go against its stated position that no energy from coal or other carbon intensive processes shall be included in the renewable energy portfolio unless it is approved through the RPS summary to CEC and CPUC. SBX1-2(2011) SB 350 (2015) and SB 100 (2018) have clarified this position. Until the RPS has completed the CPUC regulatory process and this additional carbon source included, it should not be added. 2) List the FPC as TBD with the explanation that staff have somehow modeled it but that modeling is not reflected in the ARB's page attachment "Life Cycle Emissions" report is troubling and again, the application held until this is clarified. 3) In the ARB's page attachment "POET Biorefining - Big Stone Big Stone, South Dakota Simplified Calculator for Starch and Fiber Ethanol (B0174)" ARB's hyperlink ( https://ww2.arb.ca.gov/resources/documents/lcfs-life-cycle-analysismodels-and-documentation) to this so-called "simplified calculator" leads to a dead end "page not found" message and so is impossible to comment on.
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Date and Time Comment Was Submitted: 2021-09-07 17:04:46
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