This comment is for the proposed ACC II Regulation.
- Alternatives to the proposed regulation were submitted to CARB
in a timely manner.
- Those alternatives, if implemented, would achieve reductions
in atmospheric "pollutants" far greater than the reductions
achievable by the proposed regulation.
- If the proposed alternatives were implemented in lieu of the
proposed ACC II regulation, the reduction in atmospheric
"pollutants" would be so great that the entire California EPA motor
vehicle emission waiver system would no longer be required.
- CARB staff is required by CEQA to analyze all environmentally
superior alternatives submitted for the proposed ACC II regulation,
and CARB staff is required to compare the environmental benefits of
the proposed alternatives to the environmental benefits of the
proposed regulation.
- It would be unlawful for EPA to grant a waiver to California
for the ACC II regulation if the state failed to analyze
environmentally superior alternatives to the proposed regulation,
or the state prepared a misleading/fraudulent analysis.
Tom Becker
Buellton, CA