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Comment 1 for Mandatory Reporting of GHG Emissions (ghg2016) - 15-1.

First NameJOHN
Last NameSAVAGE
Email Addressjohntsavage@gmail.com
Affiliation
SubjectGWP of Short-Lived Pollutants
Comment
Despite its long-standing leadership on climate, one important area
where ARB's climate policies have lagged behind both US federal and
global standards is in regard to its use of outdated GWP's for
short-lived pollutants.

Now, despite its proposed changes to update some of these GWP's,
ARB will continue to be a laggard in this area, which is
disappointing given the increasing importance scientists are
placing on short-lived pollutants in the overall climate change
picture.  

By the time ARB implements its proposed changes, the EPA and UNFCCC
may well have moved to, at minimum, the AR5. It seems like ARB will
always be out of lockstep with national and international reporting
when that really shouldn’t be the case.  California should continue
to lead, not lag.

Please consider using the most current GWPs going forward rather
than continuing to lag behind the rest of the world in this
important area. 

Attachment
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Date and Time Comment Was Submitted 2017-01-04 13:36:21

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