Comment Log Display

1.	Set More Aggressive Targets: The goals and regional targets
recommended in the Draft Scoping Plan are far too low to achieve
necessary reductions in greenhouse gas emissions. 

2.	Make Municipal Participation Mandatory: The local government
section emphasizes that municipal governments are essential to
achieving California’s greenhouse gas goals, but participation in
AB 32 remains voluntary. Voluntary participation ensures that only
those municipalities already committed to greenhouse gas reductions
participate. Those municipalities that currently operate under
business as usual assumptions will continue to do so.  Municipal
governments have operational and financial control over
significant sources of greenhouse gas emissions. Given the proper
requirements, we can create projects, programs, and policies that
reduce greenhouse gas emissions.  

3.	Use the Model of AB 939: Mandate the development, adoption and
implementation of local climate action plans. Municipalities need
the authority and accountability of a State mandate in order to
meet their greenhouse gas reduction targets. Local governments
should be required to develop, adopt and implement climate action
plans that are consistent with their General Plan and integrated
in CEQA documents. 

4.	Provide Funding: The cost of compliance with AB32 reporting
requirements can be burdensome for municipal governments,
especially if participation in AB 32 is voluntary. A funding
mechanism should be created to allow limited municipal funds to be
directed at projects, programs and policies that reduce greenhouse
gas emissions.  We strongly support the need for standardization
and third party verification of greenhouse gas emissions, but are
concerned that the cost of voluntary compliance will prohibit the
creation of mechanism that actually reduce emissions.

5.	Expand the Scope: The scoping plan should address municipal and
community energy, waste and recycling, water and wastewater
systems, and land use and urban design. 	

6.	Align Past and Current Reporting Protocols: The City of Santa
Monica has performed greenhouse gas emissions inventories starting
in 1990. Many leading municipal governments have done the same.  In
order to utilize this data in a meaningful way, we suggest the
creation of a standard coefficient to translate historical
greenhouse gas emissions data to be consistent with the current
model assumptions. 

7.	Access to Reporting Data:  The State should work with utilities
and public agencies to ensure that the data required for greenhouse
gas emissions inventories is available. Currently, there are fees
associated with procuring this data as well as a 1 – 3 month
waiting list.