Comment Log Display
Below is the comment you selected to display.
Comment 46 for Energy Comments for the GHG Scoping Plan (sp-energy-ws) - 1st Workshop.
First Name: Patrick
Last Name: Griffith
Email Address: pgriffith@lacsd.org
Affiliation: Los Angeles County Sanitation Districts
Subject: LACSD Comments on the ARB Draft Scoping Plan: Electricity and Natural Gas Strategies
Comment:
LACSD offers the following comments on the discussion concerning Electricity and Natural Gas Strategies in the Draft Scoping Plan: 1. Page C-58: The energy sector overlaps with many other GHG sectors including Local Government, Water, Recycling and Waste Management, etc. 2. Page C-62: On-site clean distributed generation (DG) to accomplish “zero net energy” buildings will be limited in the South Coast Air Basin because of stringent regulations that in effect remove reciprocating engines from the DG prime mover list. 3. Page C-64: Regulation of water efficiency by the CEC is redundant. 4. Page C-73: Besides market barriers, significant regulatory barriers stand in the way of CHP reaching its full market potential, not the least of which is availability of emission reduction credits (ERCs) and local AQMPs that make it difficult to install reciprocating engines running for any length of time during the day in small CHP systems. The Scoping Plan economic analysis needs to account for the reality of what “ultra-clean CHP” (Page C-75) really means.
Attachment:
Original File Name:
Date and Time Comment Was Submitted: 2008-08-11 14:20:23
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.
