First Name | Michael |
---|---|
Last Name | Huber |
Email Address | michael.huber@navy.mil |
Affiliation | U.S. Department of Defense |
Subject | DoD Cap & Trade Comments (2 of 2) - Supplemental Legal Analysis |
Comment | On behalf of the Department of Defense (DoD) Regional Environmental Coordinator for Region IX, I submit the two attached correspondence for the administrative record in support of Second Notice of Public Availability of Modified Text and Additional Documents and Information (2nd 15-Day Change Notice) on the California Cap on Greenhouse Gas Emissions and Market-Based Compliance Mechanisms Regulation, including Compliance Offset Protocols (cap-and-trade program). The 16 September 2011 letter from the Assistant Secretary of the Navy for Energy, Installations and the Environment, Ms Pfannenstiel, to ARB's Chairwoman, Ms. Mary Nichols, as well as the June 28, 2011 supplemental legal analysis supporting DoD's request for a permanent exemption. While we appreciate ARB's recognition of the issues surrounding Department of Defense participation in the cap-and-trade program, and proposed section 95852.2(c) Subchapter 10, Article 5, Title 17 of the California Code of Regulations that grants a temporary relief for emissions from NAAICS code 92811 until December 31, 2013, this temporary relief is an incomplete solution. We ask, therefore, that the exemption be made permanent in recognition that DoD will address federal mandates for the reduction of greenhouse gases (GHG). |
Attachment | www.arb.ca.gov/lists/capandtrade10/1615-dod_cap_and_trade_supplemental_legal_analysis_28jun2011.pdf |
Original File Name | DoD Cap and Trade Supplemental Legal Analysis 28Jun2011.pdf |
Date and Time Comment Was Submitted | 2011-09-27 14:17:43 |
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