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Comment 1 for Next Steps for the Post-2020 Cap-and-Trade Regulation (ctoct122017wkshp-ws) - 1st Workshop.
First Name: Gary C.
Last Name: Rynearson
Email Address: grynearson@greendiamond.com
Affiliation: Green Diamond Resource Company
Subject: Implementation of AB 398- Geographic Sourcing of Offsets
Comment:
At the recent Oct 12, workshop a question was raised about the geographic sourcing of offsets given the statute at Sec. 38562(c)(2)(E)(i)(I)and(II)state: "no more than one-half may be sourced from projects that do not do not provide direct environmental benefit in the state". There was a suggestion that this term was interchangeable with "in state" verses "out of state" sources of offsets. AB 398 does not use the term "in state". Rather, it defines "direct environmental benefits in the state" as follows: "...are the reduction or avoidance of emissions of any air pollutant in the state or the reduction or avoidance of any pollutant that could have an adverse impact on waters of the state." This definition allows offset projects neighboring California to be considered on a case-by-case basis rather than an outright exclusion of all projects that are not located in-state. Rather than reinterpret the intent of the Legislature, the exact language from the statute should be used in regulations. Thank for the opportunity to provide comments. Gary C. Rynearson, Manager, Forest Policy and Communications Green Diamond Resource Company
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Date and Time Comment Was Submitted: 2017-10-24 12:23:14
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