Comment Log Display

The Air Issues and Regulations (AIR) Committee of the Bay Area
Clean Water Agencies (BACWA) is a coalition of San Francisco Bay
Area Publicly Owned Treatment Works (POTWs) working cooperatively
to address air quality issues. The AIR Committee has 18 member
agencies, including large metropolitan facilities such as East Bay
Municipal Utility District, the City and County of San Francisco,
Central Contra Costa Sanitary District, and the City of San Jose.
Together, AIR Committee member agencies treat over ninety percent
of the municipal wastewater in the Bay Area.

We understand that the goals of the proposed Mandatory Reporting
Staff Report are to 1) begin reporting the most significant GHG
emissions, 2) use rigorous and consistent emission accounting
methods, 3) provide verification of reported emissions data, and
4) use the standards and protocols of the California Climate
Action Registry (CCAR) to the extent feasible and appropriate. The
proposed Mandatory Reporting may potentially have a large impact on
our member organizations.  Therefore, we have reviewed the proposed
Staff Report, and have summarized our concerns, as follows:

1)	In general, we are concerned that the proposed report may not
set clear dates for reporting deadlines.  As currently written in
the proposed report the reporting dates for ARB (April 1, June 1)
do not match with CCAR (August 31). This discrepancy makes
reporting to two separate state agencies more cumbersome. For
further continuity and ease in the reporting process, the
reporting dates for CARB and CCAR should align.
 
2)	Mandatory Reporting may not give enough precedence to the
biological (“biomass”/”biogenic”) portion of air emissions. As
most of our member agencies are producers of biomass or
biologically formed materials, we would like to comment on the
reporting of biomass-derived emissions. Of particular importance
is the differentiation of GHG emissions (whether biomass or fossil
fuel). We ask that a clearer distinction be made in the reporting
between biomass and fossil-fuel derived emissions to minimize any
possibility of accounting confusion when mandated emissions
reduction and cap and trade programs take effect.

We appreciate the opportunity to comment on these draft
regulations and look forward to working with you as this
regulation takes shape.  Please contact Jim Sandoval at (831)
425-7142 or Meghan Hartman at (510) 587-7547 of CH2M HILL with any
questions related to these comments.  Thank you for your
consideration.

Air Issues and Regulations Committee
Bay Area Clean Water Agencies
P.O. Box 24055, MS 702
Oakland, CA 94623