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NOTE: an illustrated and source-linked version of this comment is
available at
http://bioconversion.blogspot.com/2008/07/ca-draft-scoping-plan-comment-challenge.html
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Achieving the goals of this Climate Change Scoping Plan (an
ambitious 30% reduction of greenhouse gases projected for 2020)
will require major changes in the status quo fossil fuel paradigm
- not only how electricity and biofuels are produced, but also the
manufacture of a generation of new bioproducts based on biobased
chemicals to replace fossil-based ones. 

We live in the most dynamic state in the U.S. with research,
manufacturing, investment capital, manpower, infrastructure, and
natural resources that are the envy of the world. This combination
has led to the achievement of many paradigm shifts in the past -
aerospace, atomic energy, computers, software, telecommunications,
biotechnology, and the internet. We are poised to develop the next
paradigm in energy coupled with environmental sustainability.

However, to achieve our goals will require flexibility in our
permitting standards. Currently, the choke point on energy and
environmental technological deployments are held by state agencies
- particularly CARB - housed in Sacramento. Our standards have
become so idealistically high - i.e., Zero waste, Zero emissions -
that promising technologies cannot be permitted for deployment
within California. Specific examples include conversion
technologies using thermochemical means that can convert municipal
and environmental waste into carbon-neutral fuels and power.

The thresholds for permitting must enable promising innovations to
be deployed. Without deployment most technologies will never be
refined at commercial scale to approach delivering the highest
standards expected by the idealists. 

I recommend a graduated permitting scheme be developed by CARB for
technologies of promise. Instead of comparing performance to an
idealistically high set of standards, let's first compare them to
the status quo. If, after deployment, the technologies cannot meet
the graduated standards specified, the businesses can lose their
permit to operate. But let's encourage deployment of first
generation technologies in California.

Without deployment of promising technologies, the aims of this
Scoping Plan will fail and the status quo will remain.