Public Information Services Team
Office of Transportation and Air Quality
2000 Traverwood Drive
Ann Arbor, MI 48105-2195

Thank you so much for your politically correct reply.  There is a level of awareness in the letter that suggests the author has some engineering credentials and the experience to apply the knowledge.  Also, I will share that I spent a great deal of time in Ann Arbor years ago – I have fond memories of good times and wonderful people.

I must take exception to the statement contained in your reply below as the US Government does take sides in promoting specific technologies and solutions.  When federal funding is made available for any specific technology, the government is taking a position.  The 15% ethanol blend EPA announcement on 2010-10-13 is a major statement as E15 can no longer credibly be labeled “gasoline”.  The continued $.51 gallon ethanol blender incentive is certainly taking a position.  The tax incentives and cash-back offers for EV’s and hybrids are strong evidence our federal government is supporting these technologies.

A common published perspective of Economists and Analysts is that the current global recession shares the same cause as the last 5 recessions – the price of petroleum.  Petroleum has been the largest traded commodity in the world for almost 100 years so even a small change in price has a rippling and compounding impact on world GDP and a large change will have a staggering and long term effect on world GDP. The current recession is the most severe compared to past recessions simply because the 2008 petroleum peak price was the historic record high. The looming “double dip” or a full blown depression will also be the result of the continued soaring petroleum prices. Though the price of petroleum dropped from its 2008 $147 barrel peak down to the high $40’s, trading recovered to the low $90’s months ago and has been consistently in the mid $70’s to low $80’s since. Respected petroleum analysts are projecting a $100 barrel price again within the coming months and the impact this will have to the already weak global economies will not have been experienced since the Great Depression.

There is no legislative policy, no change in party control, no new brilliant political agenda and certainly no government cash bailout to flailing industries that will solve our current economic problems. We continue to live (granted – now at a more humble level) in a petroleum economy.

We must solve our petroleum problem to solve our economic problem as the former continues to be the catalyst of the latter. 

We must solve our petroleum problem to solve many of our environmental problems as the former continues to be a catalyst of the latter.

At $38-$43 barrel equivalent, 2nd Generation feedstock sourced biodiesel is the only tool we have today that will accomplish this critical objective.  Ethanol, EV’s and Hybrids and even 1st generation feedstocks for biodiesel contribute to the problem per a list of reasons:  top engineering talent focused on short lived technologies, federal funding subsidizing solutions that are not long term or economically viable, finite resources being depleted at historic rates, …, these are only distractions to the mainstream future of transportation.  The 2nd Gen feedstock orchards are now producing over 1,000 gallons/acre/year with significant projected per-acre production increases over the coming decades. There are nearly 100 agricultural companies in the southern states executing on business plans and planting millions of acres of orchards with a target of 24B gallons/year of sustainable biodiesel within 6-7 years. This is the equivalent volume of petroleum the US purchased from OPEC nations in 2009.

For perspective and your amusement, here is a note I recently sent to the author of an article evaluating the new Prius model:

Sanity check:  Sir, you have become engrossed in an effort to evaluate a vehicle that offers a safety rating that is below the industry average, a passenger comfort level that is below the industry average and a performance level that is below the industry average with the motivation of getting higher MPG from a finite fuel source that may no longer be sold in the US within the next 6-8 years.

Please consider writing the words, “Mineral Hog” in large letters on the windshield and return it to Toyota.

We love the Prius design – we are waiting with anticipation for the day they replace all the hybrid hardware with a B100 compatible advanced diesel engine that will achieve 75mpbg (Miles Per Biodiesel Gallon) off the assembly line offering considerably better safety, performance and lower emissions – powered with a totally sustainable, environmentally friendly, zero carbon life cycle fuel.

Now the EPA is considering a 62mpg requirement by some far off year in the future.  Let’s break this down.  There are only a few thousand engines being manufactured for the US vehicle market today.  If only 1,000 engines are developed with this 62mpg target at the typical $1B R&D capitalization to get to assembly line production status, this totals $1T (1,000 x $1,000,000,000 = $1T).

If the same amount of funding the auto industry will have to invest to achieve this unrealistic MPG target was used to accelerate the sustainable, 2nd generation feedstock biodiesel production capacity, this problem would be solved in a few years and at that point, the MPG of those vehicles would not be that important – MPG is only critical when the fuel source is finite or polluting.  Frankly, a vehicle with lower MPG running on a sustainable, economically viable and environmentally friendly fuel is actually better for the economy and better for the environment.

Yes, ASTM D6751 will not be the last word in biodiesel.  We need still better standards and still better particulate filtration and they will emerge in the coming years. Please tell me as an employee of the EPA that you are well aware that the emissions from a Prius are far worse than those of a Chevy Captiva burning B100?  We are working with GM to get 5 of these vehicles imported for our company use.  Legislation needs to be changed radically and immediately to favor B100 compliant vehicles.

Some of the major air pollutants and their primary sources are:

  • Sulfur Dioxide (SO2)- Coal burning for electricity/home heating is responsible for about 60 percent of the sulfur dioxide in the air.  Refining and combustion of petroleum products produce 21% of the SO2.
  • Ozone (O3) –  is a naturally occurring oxidant, existing in the upper atmosphere. O3 may be brought to earth by turbulence during severe storms, and small amounts are formed by lighting. Most O3 – and another oxidant, peroxyacetylnitrate (PAN) – come from the emissions of automobiles and industries, which mix in the air and undergo photochemical reactions in sunlight. High concentrations of O3 and PAN often build up where there are many automobiles.
  • Nitrogen oxides – Automotive exhaust is the largest producer of NOx. Oxides of nitrogen are also formed by combustion at high temperatures in the presence of two natural components of the air; nitrogen and oxygen.
  • Particulates are small (<10 microns) particles emitted in smoke from burning fuel, particular diesel, that enters our lungs and cause respiratory problems.

As our complete transportation solution includes the planting of over 10,000,000,000 14′ tall trees in the US, our efforts also claim these advantages…

Reduction of Air Pollutants Via Trees:

  • Trees remove other gaseous pollutants by absorbing them with normal air components through the stomates in the leaf surface.
  • There is as much as a 60% reduction in street level particulates when dense trees are present.
  • In one urban park (212 ha.) tree cover was found to remove daily 48lbs. particulates, 9 lbs nitrogen dioxide, 6 lbs sulfur dioxide, and 2 lb carbon monoxide ($136/day value based upon pollution control technology) and 100 lbs of carbon.
  • One sugar maple (12″ DBH) along a roadway removes in one growing season 60mg cadmium, 140 mg chromium, 820 mg nickel, and 5200 mg lead from the environment.
  • A total of 300 trees can counter balance the amount of pollution one US citizen produces in a lifetime at current levels.  With a migration to biodiesel and baseload reductions from glycerin and micro algae biomass in coal furnaces, this per-person emission level will drop by a factor so the additional 10B trees in the US has the potential to off-set the emissions of 1/10th of the US population and significantly improve our air quality.
  • 10,000,000,000 trees / 309,000,000 US pop. = 32 trees per person
  • Large scale micro algae farms in the coming decades have the potential to increase this counter balance by an order of magnitude – 100% of the US population

We do have options that are sustainable and immediately economically viable, but we must send the message to our legislators, car manufacturers and petroleum companies:

Favor high yield 2nd generation feedstocks for large scale biodiesel production, replace virtually all engines with advanced diesel technology targeting B100 fuels and retool the petroleum refineries for maximum diesel yield production.

If there is anyone in the EPA that should hear this message directly – please let me know.  I have presented to thousands of people over the past 2 years – 20 governors, state and federal legislators, Fortune 2000 CEO’s/COO’s/CFO’s, …, be happy to help educate – this is important – very important.  It is the only viable solution to our nation’s petroleum problem that will also stabilize the US economy.

Thank you,

Steve Frazer

Stephen Frazer, CEO
Emerging Technology Corp.
Green Division
Boulder City, NV

On 2010-10-14 2010-10-14 09:11AM wrote:

Mr. Frazer,

Thank you for your inquiry regarding electric and hybrid vehicles.  EPA shares your justified concerns for the health and well-being for all people.  EPA has been directed by the Obama administration to conduct a technical study of all light-duty transportation technologies available now through model year (MY) 2025 and beyond.  EPA has used this research as a basis for the MY 2012-2016 greenhouse gas rule finalized earlier this year, and also the upcoming rulemaking recently announced in our Notice of Intent (NOI), conducted jointly with the National Highway Safety Administration (NHTSA).  Many available and practical technologies are presented in the NOI and Technical Assessment Report that together raise the efficiency of 2020 internal combustion vehicles to the level of hybrid vehicles available today.  EPA’s direction is to present the most cost-effective vehicle technology combinations to benefit the consumer and the environment.

I read with interest the article, “EV’s and Hybrids are not our future,” mentioned in your correspondence.  The article brings up many valid points that indeed warrant further study as the demand for limited resources change.  Rare earth element supplies are indeed a hot topic today along with matters relating to vehicle electrification and upstream emissions.

The article also points out many facts regarding the ability of diesel engines to burn a multitude of fuels derived from renewable and non-renewable sources.  A steady supply of renewable low carbon fuels would be an excellent technology to add to the options for future vehicles.  This is a complex subject as standard fuels with known specifications must be available in order to function correctly with the engine calibrations and aftertreatment systems of modern vehicles.

EPA remains technology neutral in its analysis and does not promote any particular technology.  We present the most practical solutions given the technologies available and continue to seek input from all stakeholders—public and private—to gain knowledge regarding technologies for reducing pollution and reducing our dependence on finite resources for the benefit of all.

We hope this information is helpful. Thank you for contacting the Office of Transportation and Air Quality.

Public Information Services Team
Office of Transportation and Air Quality
2000 Traverwood Drive
Ann Arbor, MI 48105-2195



Date: 10/01/2010 03:49 PM

Subject: Your EPA Inquiry – (273154943) – EV’s and Hybrids are not our Future – OTAQ Web

I worked for the government for more than a decade and was amazed at the lapse in time of my fellow workers to get around to reading reports from other US Government agencies and the reports from the governments of other nations that radically effected our department’s decision matrix.

The issue currently in such a “time lapse”, will have the greatest potential for operational impact I have seen.

While you are touting the large scale migration to EV’s and Hybrid vehicles, environmentalists are mounting widespread rallies to shutdown EV and Hybrid manufacturing around the world – soaping every car with a hybrid label with the words, “Mineral Hog”.

Trading finite petroleum for finite minerals is less than a good idea.  You folks need to understand that it will be many years before the US produces even 1 ounce of rare earth minerals and that may require the DoD issue a National Security decree.

Steve Frazer
Article: EV’s and Hybrids are not our Future
Emerging Technology Corporation
EV’s and Hybrids are not our Future



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