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Comment 67 for Land Use Comments for the GHG Scoping Plan (sp-landuse-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: Local Government
Comment:
LACSD offers the following comments on the discussion concerning Local Government Actions and Regional Targets in the Draft Scoping Plan: 1. Page C-42: We remain very concerned about how local governments will allocate responsibility for emissions inventories and emissions reductions to sources under their jurisdictions without a significant possibility of double-counting. This seems to be particularly the case as the local government source category is further refined into “community” level analyses. To examine a case in point, please provide some explanation of how a regional local government program meshes with Community Energy and Community Waste and Recycling concepts articulated on this page. Local community actions can also be difficult to calculate from a credit standpoint in the case of regionally operated waste disposal facilities. Energy recovery from these programs needs to be allocated on some basis to the respective communities under the regional government umbrella. Please see our July 18, 2008 comment letter on CCAR’s Local Government Operations Protocol on this issue. We think it is very important that CARB abide by its promise at the very bottom of page 32 of the Draft Scoping Plan that “ARB will work with local governments to reconcile local level accounting with state and regional emissions tracking as the Scoping Plan is implemented.” 2. C-45: We strongly believe that CARB should input into California Office of Planning and Research and the Resources Agency that actions taken in accordance with the Scoping Plan should be categorically exempt from a GHG analysis component of any environmental document that is prepared for a project. 3. C-51: The ARB has stated many times that if push comes to shove, compliance with health-based criteria pollutant regulations will have priority over GHG considerations. With that in mind, we wonder about the benefit of performing GHG calculations as part the Subsurface Cleanup Technology discussion that the SWRCB may implement. Irrespective of the amount of GHG emitted by RTOs, for example, the elimination of groundwater contamination will always take precedence. The ARB should weigh in on decisions like these made by other state agencies and at least attempt to streamline or reduce unnecessary exercises required by other state agencies.
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Date and Time Comment Was Submitted: 2008-08-11 14:15:41
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