This is a corrected version of a comment submitted earlier.
1- The SIP contains several strategies for reducing ground level
ozone and other pollutants.
2- The SIP contains strategies, standards and regulations that
have or will require a CAA 209(b) waiver from US EPA.
3- Two of those strategies that require EPA waivers are the ACC
and ACC II regulations.
4- The emission reductions the state is achieving or wishes to
achieve from the entire CAA 209(b) program, which includes the ACC
and ACC II regulations, can be achieved without the CAA 209(b)
program by replacing all current CAA 209(b) standards with
applicable EPA standards, not implementing any new CAA 209(b)
standards and reducing statewide VMT 30% from a 2019 baseline by
2030 and 55% by 2040. In other words, the entire CAA 209(b) program
is no longer needed.
5- As part of the state's SIP review/update, I am submitting an
alternative to the entire CAA 209(b) waiver program. I request CARB
staff prepare an analysis comparing the emission reductions
achievable from all current and proposed CAA 209(b) strategies to
the alternative found in in comment #4. This request is made
pursuant to CEQA requirements, as well as EPA requirements under
CAA 209(b)(1).
Thank you
Tom Becker