A	B	C	D	E	F	G	H	I
1	__id	first_name	last_name	email_address	organization	state	comment	additional_document_name	additional_document_url
2	40	David	Breen	David.Breen@PortofPortland.com	Port of Portland	Oregon	comments attached	2014-11-20 Proposed Clean Rule Rules Port Comments (F).pdf	https://data.oregon.gov/views/twr8-72et/files/mQa895LzFwGlnGsak7jSouUqgUgDrT8EVbec8_2r1n8
3	15	Alex	Menotti	amenotti@airlines.org	Airlines for America	Washington, DC	Attached please find Airlines for America's comments on the Clean Fuels Program Phase 2 Rulemaking. Sincerely, Alex Menotti	A4A Comments on Oregon Clean Fuels Program 11-7-14.pdf	https://data.oregon.gov/views/twr8-72et/files/75y3W_zWtj1bUssCSMqrz-Vie5H4VdMSXFspFtnOEto
4	37	Rod	Blackman	grblackman@aol.com	Blackman Farms, Inc.	Oregon		DEQ LCFS LETTER.doc	https://data.oregon.gov/views/twr8-72et/files/PItw5NpVpa3b1GmWRWAhLwLD1P2wKBAg2O0b0etNxSY
5	11	Bob	Thomas	orforester@hotmail.com	ABATE of Oregon, HOG,	Oregon	Please do mot increase the amount of Ethanol in gas. My motorcycles do not run on that stuff. My wife and I drove across country to SD and MT this past spring, we got the best fuel economy our 2012 Camry ever got...no ethanol fuel. You are wasting more gas than you are saving. I get 20% less fuel economy with ethanol.
6	38	Rod	Blackman	grblackman@aol.com	Blackman Farms, Inc.	Oregon	See attached document	DEQ LCFS LETTER.doc	https://data.oregon.gov/views/twr8-72et/files/PItw5NpVpa3b1GmWRWAhLwLD1P2wKBAg2O0b0etNxSY
7	35	Alan	Journet	alanjournet@gmail.com	Southern Oregon Climate Action Now	Oregon	I write on behalf of SOCAN. As you can imagine, our volunteers are particularly concerned about global warming and the climate chaos it is causing. The evidence is clear. By 2027 we need to be totally weaned from fossil fuels just to keep the warming to 2 degrees C above pre-industrial levels. This means governments at all levels should do whatever they can to help reduce the use of polluting fossil fuels. The Clean Fuels program is exactly such a proposal. We strongly endorse this effort and encourage a rapid implementation of 2009 HB 2186.
8	17	Katie	Fast	katie@oregonfb.org	Oregon Farm Buerau	Oregon		Clean Fuel Comm.docx	https://data.oregon.gov/views/twr8-72et/files/2hlRYRucEP7anb6Y_XPCI76r4TwspE5R32e3JvBjAGQ
9	45	Jan	Koninckx	Jan.Koninckx@dupont.com	DuPont	Delaware		OR Clean Fuels_CS testimony_112514.pdf	https://data.oregon.gov/views/twr8-72et/files/nS_QDmvMVYToN4OcBAt3DYDMsMgQUrbu4xIpUoI90F4
10	34	Donnie	Jenck	michelle@jenckfarms.com	Mr.	OR	Based on our research of the proposed clean fuels legislation and our experience with the reduced fuel efficiency and added maintenance costs of the new "cleaner" engines, we urge you to look objectively at this issue and the net gains to greenhouse gas emissions as well as the unintended costs associated with these changes. Attached is an excellent report outlining our objection to this bill.
11	31	Jana	Gastellum	janag@oeconline.org	Oregon Environmental Council	Oregon		OEC CFP Phase 2 Letter of Support.pdf	https://data.oregon.gov/views/twr8-72et/files/owjNgLRYzJPxgH439oDFm7J3RujxPEn2Dlwjf8dpqqw
12	8	Robert	Krueger	Melisa@FSEco.com	First Strike Environmental	Oregon		DEQ - Fuel standard.docx	https://data.oregon.gov/views/twr8-72et/files/fjq4QkIPDMZ-iKlRQcbJoL66kKDJxYkUCC2zHa4vdZ4
13	46	Gordon	Challstrom	gordon@cwconcrete.com	Resident	Oregon	While everyone wants clean air, we must not destroy our economy in pursuit of minimal gains. As a resident of Oregon in the 60's and 70's before the Clean Air Act, there is no doubt we have achieved great strides in cleaning up our air. We need to do a cost analysis to be sure we don't destroy whats left of our economy. With the legislature proposing a mileage tax on drivers instead of the fuel tax, we could price ourselves out of the market. Already, Oregon's taxes are too high and regulations too numerous that these policies deter business from moving to Oregon. Further regulations will lead to lower pollution emissions by way of reduced industry and jobs in Oregon. The net result is an even lower medium income for all Oregonians coupled with ever higher energy prices which further squeeze Oregon family budgets. Remember to put Oregon families into the equation when proposing new burdensome rules that provide minimum results at a high cost to our economy and jobs. What good is clean air if you can't feed or house your family? Take a holistic approach that values self sufficiency and freedom instead of dependence and limited opportunity.
14	6	Ken	Morgan	kmorgan@teslamotors.com	Tesla Motors	CA	Support for Clean Fuels Program Phase 2 Rulemaking
15	43	Atul	Deshmane	atul@whole-energy.com	Whole Energy Fuels Corp	Washington	Whole Energy has operated in the biodiesel industry in Washington, Oregon, and California since 2006. We have seen firsthand the effects of clean renewable fuel policy at the state and federal level. We have been in the industry since its inception, and are currently the largest privet distributor of biodiesel on the West Coast. Clean fuel standards do more than just lower the pollution intensity of a state’s transportation system. They provide support for the development of new technologies that improve in efficiency with each new generation. They promote the conversion of waste products from industry into fuels and energy. They fundamentally shift the focus of the fuels industry from global markets to domestic independence, keeping dollars spent on fuel production in state. We wish to add our voice in support of the Oregon Clean Fuels Standard. This policy has the potential to be the best of its kind in the US. We encourage Oregon to look to the projects in California and British Columbia to learn from their mistakes and to view a case study on how this policy will truly affect retail prices for the consuming public. Oregon’s long standing support of clean fuel and progressive approach to air quality mitigation create an ideal working condition to nurture a developing project and lay a foundation for the future of energy in our country.
16	22	Jeremy	Martin	jmartin@ucsusa.org	Union of Concerned Scientists	D.C.	See attached file	UCS Comments on OR CFP Rulemaking.pdf	https://data.oregon.gov/views/twr8-72et/files/e7dbhqMGndUhL7R6BtYkaBm9fNHSrwstDZyCfT7oUoY
17	23	Ann	Gravatt	ann@climatesolutions.org	Climate Solutions	Oregon		Climate_Solutions_Clean_Fuels_Phase2_Rules_comments_Nov_7.pdf	https://data.oregon.gov/views/twr8-72et/files/5qjDk4WNaMVW0B30o31xAdli8BVWlnLaWtywKlOwPd8
18	36	Geoff	Cooper	gcooper@ethanolrfa.org	RFA	DC	Please find attached a study conducted by Iowa State University examined actual land use changes from 2004-2012. Empirical land use data are compared to ILUC results from California's GTAP model, as well as EPA's ILUC modeling results. The study's main conclusion is that: "The pattern of recent land use changes suggests that existing estimates of greenhouse gas emissions caused by land conversions due to biofuel production are too high because they are based on models that do not allow for increases in non-yield intensification of land use. Intensification of land use does not involve clearing forests or plowing up native grasslands that lead to large losses of carbon stocks."	14sr109.pdf	https://data.oregon.gov/views/twr8-72et/files/OalCVpv1e9FBbeyz7Wwk1dY56jf03nZXtpbQp8Uv1Qw
19	50	Jana	Gastellum	janag@oeconline.org	Oregon Environmental Council	Oregon	Attached please find a business coalition letter in support of the Oregon Clean Fuels program. Business support is from both within Oregon and throughout the region.	Clean Fuels Business Sign On Letter updated final.pdf	https://data.oregon.gov/views/twr8-72et/files/Je6YsKsgjz9XgqXR7jwRvbF6IgDeDt4orORBFwhrz7A
20	25	Patricia	Jermov	pjermov@yahoo.com	citizen	OR	You have done a mountain of work based on the Longest Weather Report in the World (Climate Change.) kidding aside, the Gov's proposal is essentially an emissions tax that will add about .19 cents a gallon to gas prices and who knows how far that will rise over ten years. what will happen when credits are over-sold ?Their value could drop to zero? A delay in implementing this tax under the current economy is recommended . why raise the cost of energy now when 1.) we have had a DECREASE in global temps for the last 18 years and 2.) Most of the general public is clueless that Phase 2 is coming to cash in on their pocketbook let it sunset or at the very least delay implementation for more public imput. Sincerely, Patricia Jermov
21	42	Steven	Harrington	sharrington@oda.state.or.us	Oregon Department of Agriculture	Oregon	Cory, after seeing how the text of my comment rendered I thought it best to submit an attachment with better formatting. The content is exactly the same as my previous.	340-253 Clean Fuels Program Phase 2.pdf	https://data.oregon.gov/views/twr8-72et/files/xfePzwhdtsTyzoBUKYRX9KChIlgBZB_OWTEU8_yHaGI
22	51	Shanna	Brownstein	shanna.brownstein@nwnatural.com	NW Natural	OR		CFS Comments 112514.pdf	https://data.oregon.gov/views/twr8-72et/files/LVPXmty0_7-gu8qzCZWuU1EmclNH2fVs43XaccrXC10
23	24	Mike	Salsgiver	mikes@agc-oregon.org	AGC	Oregon	Please see attached letter.	AGC Letter to EQC 11.4.2014.pdf	https://data.oregon.gov/views/twr8-72et/files/vvFl0e8qybRc-uBgtHz9MVL9kOjp3_jZLrA2sJhv3FM
24	29	Cathy	Reheis-Boyd	cathy@wspa.org	WSPA	Western States		BCG comments on ODEQ Phase 2 Rulemaking 7 Nov 2014 .pdf	https://data.oregon.gov/views/twr8-72et/files/OTpziT-BuZGCaJfyJRXh6DebrbkIK6k1qMwl4iUGGpU
25	41	Steven	Harrington	sharrington@oda.state.or.us	Oregon Department of Agriculture	Oregon	Cory, My intention in these comments is to address the definitions in the proposed rule changes to OAR 340-253. There are minor changes proposed to -0200 and -0400 which accompany the suggested definition changes. ----------------------- Definitions ----------------------- The terms “Clear Gasoline� and “Clear Diesel� appear in 340-253-0400 and in the referenced carbon intensity table. Consider adding definitions for these terms. * “Clear Gasoline� means gasoline that has not been blended with a renewable fuel. * “Clear Diesel� means diesel that has not been blended with a renewable fuel. I suggest definitions for gasoline and diesel fuel that reference the relevant ASTM standards and allow the gasoline and diesel substitute definitions cover everything else. That will keep the definitions for these terms in this rule in line with the rest of the state; * “Gasoline� means a spark ignition engine fuel conforming to the specifications defined in ASTM D 4814. Please Note: D4814 does not restrict the quantity of ethanol or any other renewable fuel blended in the motor fuel. ASTM is intentionally vague on the exact composition of gasoline. * “Diesel Fuel� means a compression ignition engine fuel conforming to the specifications of either ASTM D 975 or ASTM D7467. Please note that this defines diesel fuel containing up to and including 20% biodiesel by volume. D975 covers blends of biodiesel from 0-5% and D7467 covers blends from 6% to 20% by volume. Both documents describe specifications for "Diesel Fuel Oil". ------ Fast forward to 340-253-0200 with these proposed definitions; ------ Regulated and Clean Fuels (1) Applicability, (stuff deleted - no change recommended) (a) Gasoline; (b)Diesel Fuel; (c)(delete this item, the new gasoline definition includes ethanol blending) (d)(delete this item, the new diesel fuel definition includes biodiesel or biomass based diesel blending) (e) Denatured Fuel Ethanol (drop the E100) (f) Biodiesel (drop the “neat� and B100) (g) Biomass-Based Diesel (again drop the “neat� and B100) (h) Any other liquid or non-liquid fuel not listed in section (3) or exempted under OAR 340-253-0250. ------ “neat� in the above list doesn’t have a formal definition and so is potentially meaningless. The term Denatured Fuel Ethanol has the exact same meaning as Ethanol per the definitions and refers to the ASTM D 4806 specification which includes standards for purity. The same comment applies to Biodiesel and Biomass Based Diesel as they refer to ASTM D 6751 which contains standards for purity. Blending or dilution really isn’t an issue within this list. ------ Fast forward to 340-253-0400 with these proposed definitions ------ Fuel Carbon Intensity Values (1) Statewide carbon intensity values (a) Regulated parties, credit generators and brokers must use the statewide average carbon intensity values in Table 3 or 4 under OAR 340-253-8030 or -8040as applicable, for the following fuels; (A) Gasoline (the new definition covers both blended and unblended fuels) (B) (delete this item) (C) Diesel Fuel (the new definition covers fuels blended with up to 20% D6751 compliant blending stock) (D) (delete this item) (the remaining list is unchanged except for numbering) ------ Back to the definitions; I suggest altering the definition of “renewable diesel� to reference ASTM D 975 implicitly through the definition for the term “diesel fuel� and will guarantee that its meaning is consistent with that of diesel fuel. * “Renewable Diesel� means diesel fuel derived from vegetable oils, animal fats, or other non petroleum resources. The definitions involving natural gas seem awkward to me, especially when we start talking about “liquefied-compressed natural gas� since this term describes a process rather than a product. It can be cleared up as follows; Define the terms “Bio-Based� and “Fossil� * “Bio-Based� means produced from non-petroleum, biological renewable resources. * “Fossil� means derived solely from petroleum or fossil sources such as oil fields and coal beds. Drop the definitions for: - Bio-Based Liquified Natural Gas - Bio-Based Compressed Natural Gas - Bio-Based Liquified-Compressed Natural Gas - Fossil Liquefied Natural Gas - Fossil Compressed Natural Gas - Fossil Liquified-Compressed Natural Gas By doing this we’ve traded 6 definitions for 2 without changing the meaning of the terms in the remainder of the text. This really clears up the meaning of the terms Bio-Based Liquified-Compressed Natural Gas and Fossil Liquified-Compressed Natural Gas. Natural gas can be compressed, it can be liquefied, but it is not both. The definition for “Liquified-Compressed Natural Gas� is clear even if the term is awkward. Its liquefied natural gas transported into the state that is re-gasified and compressed for use as a motor fuel. The original definitions for these terms do not convey this meaning. I suggest changing the definition of Biogas to the following; * “Biogas� means gas, consisting primarily of methane and carbon dioxide, produced by the anaerobic decomposition of organic matter. Landfills and digesters are examples of locations where anaerobic decomposition may occur but are not really part of the actual definition. The explanation that this is not a suitable fuel for automobiles is good information but is again not really part of the definition.
26	10	Jenna	Garmon	garmonita@gmail.com		OR	I strongly urge you to adopt these clean fuel standards to reduce the carbon intensity of our fuels in Oregon. We have a short window of time to make the changes necessary to keep our climate livable. Reducing carbon emissions from transportation is crucial, and will result in many other co-benefits such as cleaner air and local job creation. As such, I urge you to adopt these rules. Respectfully, Jenna Garmon
27	48	Pamela	Barrow	pbarrow@nwfpa.org	Northwest Food Processors Association	Oregon	See attached document	NWFPA ltr - Clean Fuels R-M.pdf	https://data.oregon.gov/views/twr8-72et/files/ZHs2ZaNew_GO_Yb_0k2j_4YIuF7o_VZiw_tCfhy7ato
28	47	Micah	Berry	Micah.Berry@chevron.com	Chevron	California	Chevron does not believe that an LCFS program should be adopted in Oregon for the reasons presented in the attached deck.	C:\Users\msxu\Desktop\Oregon LCFS Revisions 11202014_Public Submittal by Chevron.pdf	https://data.oregon.gov/views/twr8-72et/files/Y7-bNf1f10l0SqYhSO6gh0n0ySj9WL4W20ErIhEldeM
29	53	Meyer	Goldstein	goldstein.meyer@deq.state.or.us	DEQ	OR	The public comment period for this rulemaking closed on November 25, 2014.
30	13	Jim	Edelson	edelson8@gmail.com		Oregon	A critical responsibility of state government is to set product standards for market products within its jurisdictional authority. Motor vehicle fuels are no different. It is the reponsibility, indeed the duty, of Oregon to set appropriate standards for fuels puchased and consumed by its residents. The Clean Fuels Program (CFP) does exactly this – and does so in a way that meets the framework set forth by the Legislature to implement such rules. My comments will address one factor in the framework – imapact on consumers and the economy of Oregon. As a matter of disclosure, I was honored to serve as alternate member of the Phase 1 Advisory Committee for the Carbon Fuel Standard. Much analysis has been provided by opponents of the CFP. As is well known, the appropriateness of their methodology – and the subsequent economic and price impact analysis - has been questioned. One interesting facet of this is that the results produced from their analysis provide wide ranges of impact on the price per gallon of gas – but the sponsors of the research nearly always choose to publicize and testify solely on price impacts that exceed $1.00 per gallon. Of course, the independent analyses conducted by the state and its consultants show much more limited impacts on gas prices – up to a maximum of 19 cents over 10 years. This lower price impact band is corroborated by similar research conducted for the California Air Resources Board. As a result, independent econometric models done for the CFP rulemaking accurately reflect net positive benefits for Oregon’s economy. It should be intuitive that when market incentives for in-state industry and a cleaner environment are combined with an improved balance of trade, better economic conditions result. DEQ and EQC should deliberately move forward with the proposed rules to set an important product standard with the CFP. Proper product standards for motor vehicle fuels will benefit Oregon’s economy and environment – and they should not be derailed by unsubstantiated claims of its opponents. The Legislaure will have the opportunity to address the fate of CFP in 2015 – do not deprive them of full decision-making scope in this matter.
31	49	Genevieve	Cullen	gcullen@electricdrive.org	Electric Drive Transportation Association	Washington, DC		OR Clean Fuel Standard.doc	https://data.oregon.gov/views/twr8-72et/files/stV2OAs2XWblw-SVdVcll1VQh4qL7YT-GZvunVCpd-4
32	28	Ryan	Lamberg	rlamberg@biodiesel.org	California Biodiesel Initiative	California	Here are our previously submitted ICF report comments, Ryan Lamberg	NBB ICF_Oregon_Comment letter 9.12.14.pdf	https://data.oregon.gov/views/twr8-72et/files/iwaD0N8aNZJKNXoWGA8omsZEzoK_7uD1wyIUmOWZE_k
33	7	Alan	Journet	alanjournet@gmail.com	Southern Oregon Climate Action Now	Oregon	I write on behalf of over 700 activists with Southern Oregon Climate Action Now. Especially after the results of November 4th, when climate deniers were returned to DC from across the nation, it is very clear that we cannot expect very much leadership on the global warming / climate chaos front from Washington. Since greenhouse gas emissions from transportation consistently appear in the top three causes of such emissions, it is necessary that we do whatever we can to reduce those emissions. One way to do this s to reduce the carbon concentration in fuels. Efforts to implement the clean fuel standards of 2009 House Bill 2186 are applauded by all those across the state who care about the livability f the planet for future generations.
34	16	Katie	Fast	katie@oregonfb.org	Oregon Farm Bureau	Oregon		clean fuel comments.docx	https://data.oregon.gov/views/twr8-72et/files/GTlgrbJraNTf0n_UK-kGQ0WumY2Qhme1CKWtXDyhGtg
35	32	Jana	Gastellum	janag@oeconline.org			Attached please find a business coalition letter of support for the Clean Fuels Program	Clean Fuels Business Sign On Letter final.pdf	https://data.oregon.gov/views/twr8-72et/files/hLXMxKEkaDL4i375qHQs2EIjdmPqK_vR0zCNb11k258
36	5	Willie	Tiffany	williet@orra.net	Oregon Refuse & Recycling Association	Oregon	See attached letter.	Clean Fuels Phase II Rulemaking - ORRA coments.pdf	https://data.oregon.gov/views/twr8-72et/files/e6cgTgC5aCgPxBnMyCNABTOJcbv11hZecGwGItk-gTs
37	27	Ryan	Lamberg	rlamberg@biodiesel.org	California Biodiesel Initiative	California	Hello Cory, After this, we are submitting another letter previously submitted regarding the ICF report. All the best, Ryan Lamberg	NBB Phase 2 Comments 11-7-14.pdf	https://data.oregon.gov/views/twr8-72et/files/8YYeNqp_7lze_Hg6OScugFsSOCq-xii2Cb4_qNiszWM
38	26	Jessica	Hoffmann	jwhoffmann@rpmgllc.com	RPMG, Inc.	Minnesota	Written comments in attached pdf.	RPMG, Inc. Comments CFP Proposed Rule Making.pdf	https://data.oregon.gov/views/twr8-72et/files/EMvCyCYA9oWNwfGzwffy-7H5hHipiCIC9U0ktKRG9zk
39	3	Tucker	Ruberti	tucker.ruberti@aei.com	AEI	OR	Hi DEQ Team, I have been involved in the energy industry for over 20 years. In my career I have never seen a solution that is more misguided than ethanol mandates. It is basically a policy of using oil, water and pesticides to create a similar fuel output in terms of energy content. I am strongly against any policy that does not deliver at least a 2-3 x EROEI (Energy Returned on Energy Invested) and ethanol struggles ot get a 1:1 EROEI. Please stop subsidizing a inefficient fuel. Sincerely, Tucker Ruberti
40	21	Ted	Kniesche	tkniesche@fulcrum-bioenergy.com	Fulcrum BioEnergy, Inc.	California	Dear Ms. Wind: Please find attached comments from Fulcrum BioEnergy regarding the implementation of Oregon's Clean Fuels Program. Thank you.	Fulcrum BioEnergy Comments - OR Clean Fuels Program 2014-11-07.pdf	https://data.oregon.gov/views/twr8-72et/files/Cv7HtymF73PNUd__8zE5W8OlT3q4fDua5Ps8eThZZt0
41	20	Geoff	Cooper	gcooper@ethanolrfa.org	RFA	DC	Please find comments attached. Thanks.	Oregon CFP Comments_RFA.pdf	https://data.oregon.gov/views/twr8-72et/files/k3KsDt1KecIu_d9zuwgTfdTVjb6GzfTzPG67_CvwKDU
42	2	Debra	Dunn	dunn@ortrucking.org	Oregon Trucking Associations	Oregon	See attached comment letter. Thank you	DEQ Clean Fuels Rulemaking Comments.pdf	https://data.oregon.gov/views/twr8-72et/files/n-FX6hkbvqC_V9S6nY1aKOWu00xrr6Tr5IOrre7Kx2E
43	44	Ross	Macfarlane	ross@climatesolutions.org	Climate Solutions	WA	The attached comments supplement our earlier written comments and the testimony provided on November 19. Thank you.	Oregon Clean Fuels Supplemental Comments (RAM 11-24-2014) (Ben Serrurier).docx	https://data.oregon.gov/views/twr8-72et/files/PQWp1JYnL8-2cViteDxRo5QETRuk5cZxKB1eQrmSC78
44	19	Graham	Noyes	gnoyes@kfwlaw.com	Low Carbon Fuels Coalition	California	Please see attached report of the UC Davis Institute for Transportation Studies which is submitted as referenced in the Low Carbon Fuel Coalition's comment.	Status Review of CA LCFS by ITS July 2014.pdf	https://data.oregon.gov/views/twr8-72et/files/uXvMqsmYKd_rEMto9GD2eJQx1Q6NyWMyqaK0bKPODlo
45	52	Kevin	Poling	polingk@gmail.com		Oregon	Please remove House Bill 2186. It will cost us consumers of fuel products way too much for an unproven return. Please listen to the Western States Petroleum Association and to Avista Utilities (Avista), Cascade Natural Gas Corporation (Cascade), and Northwest Natural Gas Company (NW Natural) comments on the effects of House Bill 2186. Thanks, Kevin Poling
46	12	KEITH	REGELIN	a8fb4853@opayq.com		OR	I urge you to NOT adopt the costly new Low Carbon Fuel Standard. It will unfairly penalize lower-income Oregonians who pay a larger share of their income on transportation, and will punish small businesses that are sensitive to high fuel costs.
47	18	Graham	Noyes	gnoyes@kfwlaw.com	Low Carbon Fuels Coalition	California	Please see attached comment of Low Carbon Fuels Coalition and report of the Institute for Transportation Studies that I have submitted as a separate comment.	Low Carbon Fuels Coalitions Comments RE OR Clean Fuels Program.pdf	https://data.oregon.gov/views/twr8-72et/files/63_BlgwOsQSvDmmxzhC6LZY62eZFO6MAS97-wIpxgBw
48	14	Michael	Brower	Shays@acore.org	American Council On Renewable Energy (ACORE)	Washington, DC		ACORE Comments OR Clean Fuels Program.pdf	https://data.oregon.gov/views/twr8-72et/files/CRBiCw22ghMhMNB-_CjiZcx_J705aMJb3OF3VYu7e7A
49	39	Richard	Moskowitz	rmoskowitz@afpm.org	American Fuel & Petrochemical Manufacturers	DC	Attached are AFPM's comments on the proposed regulations for Phase 2 of Oregon's Clean Fuels Program.	Oregon LCFS Comments AFPM112014.pdf	https://data.oregon.gov/views/twr8-72et/files/EkBKtr18dj5gtki5q00-8if7RPHHwOj6Vk_m6mx0McU
50	33	Colin	Freestone	cscura@comcast.net		OR	Ethanol is not an energy efficient additive to petroleum fuel for reasons of production cost in agriculture and mechanical efficiency. Motorcycles, which help save carbon based fuels operate less efficiently on ethanol even at the current 10% level. An increase in ethanol content will further reduce gas mileage, cause engine damage and costly repairs to or replacement of catalytic converters on automobiles.