Comment Log Display

Dear California Air Resources Board, 

The City of Palo Alto Regional Water Quality Control Plant (City of
Palo Alto) appreciates the opportunity to comment on the proposed
amendments to the Regulation for the Mandatory Reporting of
Greenhouse Gas Emissions (17 CCR §95100 et seq.).  In particular,
the City of Palo Alto supports the effort in the proposed
amendments to align this regulation with that of other
jurisdictions with greenhouse gas (GHG) reporting programs. The
City of Palo Alto recommends further action be taken within the
proposed amendments to better align the California Air Resources
Board’s (CARB) GHG reporting regulation with that of the United
States Environmental Protection Agency’s (USEPA).  

The City of Palo Alto treats wastewater collected from 220,000
residents of Palo Alto, Stanford University, Mountain View, Los
Altos, Los Altos Hills, and the East Palo Alto Sanitary District. 
The City of Palo Alto treatment plant utilizes several stationary
combustion sources that require facility reporting of GHG emissions
under the existing Regulation for the Mandatory Reporting of
Greenhouse Gas Emissions as well as reporting under the USEPA’s
Mandatory Greenhouse Gas Reporting regulation (40 CFR §98). 
Currently, the CARB GHG regulation utilizes global warming
potentials and emission factors from 2009-2011 versions of the
USEPA regulation; however, USEPA has since amended these values
resulting in significantly different emission inventories for the
same facility being reported to the two regulatory agencies.  This
discrepancy results in increased staff time for inventory
compilation as well as confusion for those not directly involved in
emission compilation and reporting such as elected officials, upper
management, and interested public stakeholders. 

 
The proposed amendments to the CARB regulation seek to align global
warming potential multipliers with that of the USEPA regulation by
incorporating as reference Table A-1 to Subpart A of the Title 40
Code of Federal Regulations Part 98, as published to the CFR on
12/11/14.  However, the proposed amendments do not currently seek
to adopt the most recent USEPA emission factors resulting in
facilities, such as the City of Palo Alto, still having
significantly different emission inventories reported to the two
different regulatory agencies. City of Palo Alto recommends that
CARB also align emission factor multipliers with that of the USEPA
regulation by incorporating as reference Tables C-1 and C-2 to
Subpart C of the Title 40 Code of Federal Regulations Part 98, as
published to the CFR on 12/11/14.  

Please do not hesitate to contact Samantha Engelage (Associate
Engineer) at 650-329-2123, or by email
(Samantha.Engelage@CityofPaloAlto.org) if you have any questions or
require additional information concerning City of Palo Alto’s
comments.

Respectfully,
Jamie S. Allen
Regional Water Quality Control Plant
City of Palo Alto