From: CleanFuelsAug2012
Sent: Wed Sep 05 10:16:23 2012
To: 'Ball Lenn'
Cc: CleanFuelsAug2012
Subject: RE: Don't move forward with the LCFS
Importance: Normal
Your comments have been received for the proposed Oregon Clean Fuels Program rulemaking. Thank you for your interest.
Cory-Ann Wind
Air Quality Planner
wind.cory@deq.state.or.us
503-229-5388
From: Ball Lenn [mailto:esmoothz@yahoo.com]
Sent: Thursday, August 30, 2012 3:58 PM
To: CleanFuelsAug2012
Subject: Don't move forward with the LCFS
The Environmental Quality Commission should not move forward with the adoption of this new regulation.
It is infeasible because the biofuels necessary to meet the standard do not yet exist in commercial quantities. Even if it were feasible, the standard will likely result in large-scale shuffling of fuels around the U.S. and the globe that will significantly reduce if not eliminate any environmental benefits. And California’s Low Carbon Fuel Standard has been declared unconstitutional by a federal judge, whose decision is currently being appealed. For all of these reasons, now is not the time to move forward with the LCFS.
Please think twice before adopting these new regulations on Oregon businesses and citizens. We have been over regulated for years and have had enough. The horrible Economic Environment should be everyones primary concern at this time. Please do not regulate more businesses and workers out of their jobs.
A LCFS in Oregon would likely increase fuel costs to small businesses. Fuel costs are an important expense for most small businesses. These businesses often rely on fleets of trucks or other vehicles to reach their customers or deliver their products. Every additional dollar that they have to pay at the pump as the result of costly new state regulations, such as the LCFS, is a dollar that they can’t use to hire additional workers or invest in their business.
A LCFS would likely cost Oregon’s economy over 29,000 jobs. Between 2007 and 2011 Oregon lost over 113, 200 nonfarm payroll jobs. A recent study showed that, by the year 2022, there could be between 9,000 and 29,000 fewer net jobs due to the LCFS. Oregon can’t afford these losses as we work to build an economic recovery. Oregon's unemployment is well above the national average.
By moving forward with an LCFS the EQC will be allowing the Department of Environmental Quality to create and implement regulations that will increase costs to Oregon businesses and result in job losses at a time when Oregon’s unemployment rate is still above 8.5%.
Thank you,
Lenn and Denise Ball
Smooth Water Construction Company
P.O. Box 578
Arlington, OR 97812