Comment Log Display

October 23, 2013


The Honorable Mary D. Nichols, Chairman
California Air Resources Board
1001 “I” Street
Sacramento, CA 95812

Re:  City of Long Beach Comments to Proposed Cap and Trade
Regulation Amendments

Dear Chairman Nichols:

On behalf of the City of Long Beach, I write to comment on Cap and
Trade Program changes that have been proposed by California Air
Resources Board (CARB) staff, and described in the Initial
Statement of Reasons (ISOR), released September 4, 2013.  The City
is supportive of the document, particularly proposed regulatory
changes that exempt Waste-to-Energy and natural gas suppliers from
the first compliance period.  However, Long Beach is concerned and
is requesting clarification of Waste-to-Energy language on page 29
of the ISOR.

Waste to Energy Exemption
The City appreciates the proposed exemption for Waste to Energy
facilities from the first compliance period.  This is consistent
with CARB Board Resolutions 11-32 and 12-33.  However, language on
page 29 of the ISOR is inconsistent with the aforementioned
resolutions, and inconsistent with proposed regulatory changes. 
This language would prevent a Waste to Energy facility's internal
load, and potentially the entire Waste to Energy facility, from
inclusion in the first compliance period exemption:

“In order to obtain the exemption, facilities must report and
verify their emissions. In addition, the electricity must be placed
on the California grid and not used to meet the facilities internal
load.”

The City does use a small amount of the energy generated at SERRF
to power the facility, but the majority of electricity is place on
the California grid.  Given this history, Long Beach requests an
amendment to the language on page 29 to ensure consistency with
proposed regulatory changes on page 96 of the ISOR.  It is our
preference that language read:

“In order to obtain the exemption, facilities must report and
verify the emissions."

Natural Gas Exemption
The City supports proposed amendments that would exempt natural gas
suppliers from the first compliance period by providing new
allowances to this industry.  Such changes will allow Long Beach to
ease its small natural gas customers into a price signal that will
promote greater reductions in GHG emissions on a gradual and market
basis.

Thank you for taking the city’s earlier comments into consideration
on the Cap and Trade Program with the establishment of CARB’s ISOR.
 Should you have any questions, please contact Tom Modica, Deputy
City Manager at (562) 570-5091.

Sincerely,



Mayor Bob Foster
City of Long Beach