Comment Log Display
Below is the comment you selected to display.
Comment 19 for Industry Comments for the GHG Scoping Plan (sp-industry-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: Industry Strategies
Comment:
LACSD offers the following comments on the discussion concerning Industry Strategies in the Draft Scoping Plan: 1. Page C-102: We question the value of energy efficiency and co-benefits audits for large industrial sources. As stated previously, given control measure MCS-01 in SCAQMD’s 2007 AQMP, most stationary combustion sources in the South Coast will be forced to BACT levels so there will be little margin left for improvement. To conduct an audit specifically to find co-benefits is not appropriate as the focus of AB 32 is greenhouse gas reduction. 2. Page C-115: In the South Coast, boiler efficiency may actually drop and GHGs increase as result of control measure MCS-01 which, in driving boiler NOx lower, is also lowering boiler efficiency thereby increasing the amount of fuel that needs to be burned to deliver the same usable output. See the Environmental Assessment for Rule 1146. The goal of increasing boiler efficiency and thereby reducing GHG emissions is thwarted by AQMPs that are solely focused on criteria pollutant reduction. CARB needs to be the arbitrator in these situations. 23. Page C-116: In the South Coast, it is difficult to install stationary internal combustion engines as prime power. We are also concerned about across the board electrification of motors as this reduces the region’s ability to respond to emergencies such as earthquakes.
Attachment:
Original File Name:
Date and Time Comment Was Submitted: 2008-08-11 14:34:12
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.