Comment Log Display

Comment Log Display

Below is the comment you selected to display.
Comment 113 for General Comments for the GHG Scoping Plan (sp-general-ws) - 1st Workshop.


First Name: Edward
Last Name: Mainland
Email Address: emainland@comcast.net
Affiliation: Sierra Club California

Subject: Big-Ticket Items that CARB's Plan Should Not Neglect
Comment:
Comments of Sierra Club California Energy & Climate Committee, 
California/Nevada Regional Conservation Committee to California
Air Resources Board      

Recommendations Regarding Implementation of AB 32 to Achieve
Reductions in Greenhouse Gas  Emissions

May 2008      

Table of Contents 1     Introduction   2  Innovative Programs  3  
Land Use Sector:  Regional Blueprint Planning, Mass Transportation 
 4  Transportation Sector:  Electrification of Transport     8 
Utilities Sector:  Community Choice Aggregation (CCA) and
Renewable  Energy    12  Waste Sector: Zero Waste Policies &
Landfill/Compost Regulations   17   Market Based Incentives  
Feed-in Tariffs    21  Setting a Price on GHG Emissions   22   
Conclusion 24        - - - - - - - - - - - - - - - - - - - - - - -
- - - - - - - - - - - - - - - 
Introduction   Thank you for this opportunity to assist the
California Air Resources Board in developing a Scoping Plan to
meet the Greenhouse Gas  emissions reductions mandated by AB 32.
In the sections below, Sierra Club California highlights emission
reduction strategies by selecting one or two innovative programs
in each of four sectors -- Land Use,  Transportation, Utilities,
and Waste -- that we believe are most likely to have positive
effects in reducing both conventional ‘criteria’ pollutants as
well as greenhouse gas emissions. There is an effort to approach
the  problems holistically, to see the interaction between
sectors, such as transportation and utilities or land use, and
also to consider solutions that work simultaneously for the
environment and the economy. Each  strategy is directed toward
three groups of stakeholders – wholesalers/manufacturers,
retailers/providers, and consumers/ ratepayers/residents. 
Afterwards, we describe and comment on two  market-based
incentives that are currently the subject of much public debate. 

Local, state, and federal governments in the US are experiencing a
growing recognition of the potential environmental, social,
political, and financial benefits inherent in adopting the goal of
near-term emissions  reductions.  The urgency of achieving GHG
reductions in the near future gives ARB an unprecedented
opportunity to strengthen liaisons among the various agencies and
planning divisions.  ARB has the potential to  simultaneously
accomplish goals along three dimensions:   decrease in GHG
emissions, further clean-up of criteria air pollutants, and
reduced reliance on imported conventional fuels. Toward these
goals, we  propose the adoption of the programs and incentives
described below.  

Urban planning that reduces driving times and avoids suburban
sprawl has been recognized as an important strategy for reducing
GHG emissions across the US.  In the recently published Urban Land
 Institute’s Growing Cooler: The Evidence on Urban Development and
Climate Change (2008), the authors warn that if sprawling
development across the US continues to fuel growth in vehicle use,
the projected 59  percent increase in the total miles driven
between 2005 and 2030 will overwhelm expected gains from vehicle
efficiency and low-carbon fuels. Even if the most stringent
fuel-efficiency proposals under consideration  are enacted, notes
co-author Steve Winkelman of the Center for Clean Air Policy,
“vehicle emissions still would be 40 percent above 1990 levels in
2030 – entirely off-track from reductions of 60-80 percent  below
1990 levels by 2050 required for climate protection.”  Clearly,
urban/suburban planning decisions go hand-in-hand with programs to
reduce GHG emissions in the transportation sector (see 
http://www.smartgrowthamerica.org/gcindex.html).  Traditionally,
land use decisions have been local prerogatives, and 18 
California counties are already using “UPlan’, a “micro-economic
integrated land use and transportation model” advocated by the
Information Center for the Environment at UC Davis.  It is on a
regional  scale, however, that California land use policies can be
meaningfully linked with more effective mass transportation
alternatives. Traditionally, transportation planning agencies have
not considered land use to be  within their effective scope.
However, the recognition that a regional approach is critical for
changing travel patterns and decreasing GHG emissions has led four
metropolitan regions -- San Francisco,  Sacramento, Los Angeles,
and San Diego – to create Regional Blueprints. The Regional
Blueprint Planning process is designed to build consensus on
practical solutions for managing growth.  In total, nine  regions,
encompassing 95% of the state’s population, are actively engaged in
Blueprint Planning.  This convergence presents an unprecedented
opportunity for incorporating innovative mass transit  programs
and infrastructure into a visionary statewide transportation
network that provides attractive alternatives to current driving
practices. (see http://climateplanca.org/climateplan_brochure.pdf
). 

Accomplishing these goals will require moving beyond “business as
usual” approaches, and it will be very useful if CARB can develop
a  working relationship with governing bodies and appropriate
staff in the state and regional transportation planning agencies.
The aim, in our view, should be to create plans as well as
meaningful  performance metrics for meeting greenhouse gas
reduction goals, and integrating these into the regular decision
processes of the planning agencies. Directors of these agencies
need to be held responsible for  implementing the appropriate
metrics and meeting goals.  At the state level, Caltrans’ Division
of Transportation Planning has  been directed— “through active
engagement with all segments of the population as well as critical
stakeholders in the community, business interests, academia,
builders, [and] environmental advocates”—to  “foster a more
efficient land use pattern that supports improved mobility and
reduced dependency on single-occupant vehicle trips.” For the
third year, Caltrans is offering monetary grant funding for
“regional  collaborative decision-making” that will lead to
providing consumers with more transportation choices and will
“[r]educe costs and time needed to deliver transportation projects
through informed early public  and resource agency involvement.” 
(see http://calblueprint.dot.ca.gov/).  A group of consultants who
have conducted studies pursuant to  Regional Blueprint directives
have calculated that Vehicle Miles Traveled (VMT) have seen a 45%
reduction, compared to the regional average, in households located
within a 1?2 mile of transit stations, and a  21% reduction for
households located between 1?2 and 1 mile of transit stations. 
Mass transit is particularly well suited for shorter trips, which
cause a disproportionately large percentage of total GHG vehicle 
emissions.  Often-cited studies have shown that 55-65% of all
trips are less than 3 miles, and up to 80% are less than 5 miles.
(See http://www.dot.ca.gov/hq/tpp/offices/opd/
past_files/Presentation_24Ds.pdf).   

Mass transit options should be accessible, reliable, and
reasonably comfortable in order to provide realistic alternatives
to the familiar allures of personal vehicle use.  With a few
notable exceptions, budget  allocations for mass transit
infrastructure in California have far under-paced government
funding for state roads and highways.  Policies in the
Transportation sector that have favored passenger vehicles and
cargo  trucking have resulted in serious traffic congestion, high
accident and injury rates, alarming levels of GHG emissions, and
problematic waste issues in the manufacturing and disposal of cars
and trucks. The  convergence of the Regional Blueprint Planning
directives and the AB 32 reduction goals affords an unprecedented
opportunity to ‘fast-track’ design and development of regional
mass transit infrastructure, including  Bus Rapid Transit
programs, expansion of existing Amtrak lines, High-Speed Passenger
Rail systems, electrified commercial transport, and accessible
siting of transit stations for neighborhood inter-modal 
connections.  At the same time, we need to begin thinking in terms
of the ‘true costs’ of driving passenger vehicles, and reduce
current incentives to driving, thereby discouraging the
‘car-centric’ way of life  that has been adopted in California and
throughout the country.  Several of these disincentives have
already been discussed and recommended in the February 2008 report
by ARB’s Economic and Technology  Advancement Advisory Committee
(ETAAC).      

Bus Rapid Transit (BRT) is an innovative program that will require
 minimal additional infrastructure, and will have the multiple
effect of enhancing service capacity within the existing highway
system while reducing VMT and GHG emissions levels. Bus Rapid
Transit integrates  bus with rail transit, while also making use
of existing High Occupancy Vehicle (HOV) lanes, priority at
traffic lights, and several other technologies to improve mobility
and efficiency. The Director of  Caltrans has asserted: “It is our
policy to transport the maximum number of people as efficiently
and cost effectively as possible through comprehensive, multimodal
‘system management’...[BRT] is emerging  as one of the most
attractive investment choices, especially since our State Highway
System presents tremendous opportunities to quickly implement BRT
services.  With one of the most extensive networks of High
Occupancy Vehicle (HOV) lanes in the world, California already has
a foundation in place to support the development of BRT operations
in our urban areas.” (See: 
http://www.dot.ca.gov/hq/MassTrans/Docs-Pdfs/BRT-Handbook-030706.pdf
 ).   The goal of maximizing usage and insuring cost-effectiveness
is also important for realizing greenhouse gas reduction in other
transportation modes, such as rail, bicycle and pedestrian. ARB
can play an effective  role in moving CALTRANS and other
transportation agencies to expand the role of these metrics, and
promote effective implementation of transportation options that
are too often short-changed in the  planning and budget process.
In addition, ARB should develop policies that assist rail and
transit agencies to move away from dirty diesel fuel to cleaner
energy sources. This will improve the environment while making 
public transportation a much more attractive option for the
public.  Developing new models to more accurately forecast
emissions is a  critical step to identifying and implementing
regional land use strategies for GHG pollution reduction. The
Sacramento Area Council of Governments (SACOG) has created one of
the most sophisticated  models in the country, and recently used
it to review a large-scale development proposal.  The Blueprint
process resulted in a scenario with 33% less water consumption, a
26% decrease in average vehicle  travel per new household, and a
7% reduction in travel time spent in heavy congestion when
compared to existing land use patterns.  SACOG is now providing
resources and incentives to help other cities  realize this vision
(see Base Case and Draft Preferred Scenario: Key Statistics,
www.sacog.org ).   The CEC’s Integrated Energy Policy Report
(2007) states that the Blueprint Planning program is in the early
stages of implementation, and will require technical, financial,
and regulatory assistance to meet its  goals of reducing climate
and energy impacts throughout the state’s metropolitan areas. The
Report encourages state agencies to assist local governments in
reducing energy use and GHG emissions.  This is one crucial area
where ARB can facilitate energy-efficient land use development
patterns by supporting the incorporation of statewide mass transit
planning into Regional Blueprints processes.  Coordination of 
efforts with Caltrans, Amtrak railways, and BTH (California
Business, Transportation, and Housing Agency) could result in
dramatic improvements in the availability, comfort, and cost of
neighborhood  mass transit stations, metropolitan-intercity rail
services, and bus rapid transit systems.    

Transportation Sector:  Electrification of Commercial, Public, and
Private Transport   Summary:  A large number of private and public
stakeholders around the world recognize that battery electric
vehicles (BEVs)  are the most feasible candidates to meet imminent
needs for Zero Emission Vehicle (ZEV) production and availability. 
Near-term electrification of all modes of transportation –
commercial, public,  and private – is an essential component for
the implementation of AB 32 goals. The urgency of reducing GHG
emissions should guide ARB to create a Battery Electric Vehicle
Partnership for fulfilling  near-term reductions, while
realistically relegating the role of the Hydrogen Fuel Cell
Partnership to long-term reductions. 

Tansportation is the largest contributor to GHG emissions in
California, currently measured at approximately 40% of the total. 
It is urgent that programs in this sector be scaled up in a serious
way in order to  contribute to the implementation of AB 32
requirements.  The February 2008 report by ARB’s Economic and
Technology Advancement Advisory Committee (ETAAC) identifies three
major areas for  “rethinking transportation to lower demand and
carbon”:  changes in private and commercial driving practices,
cleaner fuels, and new technologies. In the area of driving
practices, the report makes several  worthwhile suggestions
relating to state agencies’ revisions of roadway designs,
transportation planning metrics, and land use programs to optimize
traffic patterns.  The report also focuses on the implementation of
regulations that encourage drivers to reduce their length of miles
traveled, the number of trips taken, and time spent in congested
traffic, while promoting an increase in carpooling and mass
transit for daily  commutes.   Recognizing the large percentage of
GHG emissions contributed by  commercial trucking, freight, and
cargo services throughout California, the ETAAC Report recommends
that ARB extend its partnership with state transportation agencies
to plan commercially viable electric rail  systems that would help
replace reliance on standard diesel trucks and trains. Sierra Club
California appreciates the attention that ARB has already given to
anti-idling laws for the trucking industry, the promotion  of
on-board and off-board electrification at rest areas and truck
stops, and the regulation of diesel emissions for buses and waste
collection vehicles.  ARB has also wisely turned its attention to
the diesel  emissions of ships and trucks at California marine
ports.  However, such regulations targeting diesel and gas engine
emissions are transitional in nature, given the imperative of
achieving system-wide redesigns of  vehicle propulsion.  In order
to offset the environmental impact of population increases and
anticipated growth in the Transportation sector, it is essential
that new technologies be researched, developed,  and adopted by
government-manufacturer partnerships in an expedited manner.   The
two leading technologies that are being developed for replacing
conventional gas engines are electric- and hydrogen-powered
vehicles.  Both technologies are able to power zero emission
vehicles (ZEVs),  depending upon the sophistication of their
designs and their methods of power-source generation.  Sierra Club
California is joined by a consortium of environmental and health
organizations that is advocating  the near-term production and
availability of ZEVs as an essential component for the
implementation of AB 32.  The overwhelming consensus is that
battery electric passenger vehicles (BEVs) are the  most feasible
candidates to meet imminent needs for ZEV availability.  Future
electrification of all modes of transportation— commercial,
public, and private—is indispensable for meeting longer-term
reduction targets.  The first phase of ARB’s ZEV program has
focused on private  passenger transport, and considered only
criteria pollutants.  However, in relation to meaningful progress
toward GHG reduction goals, a substantial shortfall exists for
this first phase of electrification in the  number of vehicles
proposed. In its March 2008 ZEV revisions, ARB failed to increase
the number of ZEVs to be produced (which had been 25,000 in
2012-14 and 50,000 in 2015-17).  Instead, these inadequate 
requirements were further reduced to a paltry 7,500 ZEVs in
2012-14 by allowing “near zero” emission vehicles (plug-in hybrids
and hydrogen internal combustion engines) to substitute for “pure”
ZEVs.  Although  ARB claims that its strategy has “appropriately
considered the state of technology, market factors, economic
impact, and our mission”, Sierra Club California respectfully
disagrees and believes that there should be  hundreds of thousands
of ZEVs on the road in that timeframe.  The three main
considerations for ARB’s decision making— technological readiness,
market factors, and economic impact— have changed  considerably
since the Staff ZEV Technology Review of April 2007.              
                                                                   
                                                                   
 (see
http://www.arb.ca.gov/msprog/zevprog/zevreview/zevreview.htm).    
                                        Updated data should guide
ARB’s actions.  For example, the Staff Review estimates that
consumers will ‘break even’ on the battery costs  of electric
vehicles when gasoline prices reach approximately $2.75-$4.25 per
gallon. Gasoline prices already have hit the higher end of that
range, and battery prices are falling.  Next-generation lithiumion
batteries are being developed by a number of manufacturers in Asia,
Europe, and the US; they are being readied for commercial
availability in OEM (Original Equipment Manufacturer) car models
that will deliver  near 100-mile range.  Existing lithium-ion
batteries are also being used by non-OEM manufacturers to produce
EVs with greater than 200-mile range.  Thus, the advances and
readiness of battery technology, coupled with the economic impact
of the price of gasoline, have dramatically improved the market
picture for battery electric vehicles (BEVs) in the past year.   
Furthermore, the Staff Review is based on inaccurate OEM estimates
of the projected costs for plug-in hybrid electric vehicles (PHEVs)
and  hydrogen Fuel-Cell Vehicles.  Table 6.1 (Incremental Vehicle
Cost Estimates) relies on 2003 data for battery costs and OEM
guesswork about the cost of fuel-cell technology in 2012. The
conclusion that a  PHEV in 2012-2014 will cost $25,000 more than a
conventional vehicle is not supported by current prices.  OEM HEVs
are now being converted to PHEVs for $10,000 or less, and at least
two OEMs plan  to market new PHEVs in 2010 with an incremental cost
of less than $15,000. The conclusion that BEVs will cost from
$35,000-$65,000 (Type 1) to $80,000-$120,000 (Type II) more than
conventional  vehicles is also over-estimated. On the other hand,
the OEM opinion that a Fuel-Cell Vehicle in 2012 will only cost
$250,000-$350,000 more than a conventional vehicle appears to be
wishful thinking, given  the lack of significant progress in many
areas of Fuel Cell technology—including range, hydrogen storage,
fuel cell life, cost, etc—and  other major impediments to mass
production.    ARB's pessimistic under-emphasis on requiring auto
manufacturers to produce the necessary numbers of BEVs is
compounded by its  optimistic over-emphasis on research and
development of Fuel Cell Vehicles. The urgency of reducing GHG
emissions should guide ARB to create a Battery Electric Vehicle
Partnership for fulfilling near-term  reductions, while
realistically relegating Hydrogen Fuel Cell Partnership as an
option that may in the longer-term future (post-2020) become a
viable option for reducing GHGs. Today, Fuel Cell Vehicles should
be  considered a “risk strategy” that may not match the technology
and performance characteristics of other options in a relevant time
frame. Over-commitment to this very expensive and unripe technology
is likely  to divert funding away from more promising near-term
options, and delay real solutions for decades. This would greatly
increase the risk of failure to achieve reductions in GHGs in the
transportation sector. 6   A re-ordering of AB 32 priorities
toward increasing the production of BEVs should encompass
augmented funding for the immediate  development of plug-in hybrid
vehicles (PHEVs).  According to the Electric Power Research
Institute (EPRI), half the cars in the US are driven 25 miles a
day or less.  It is also well understood that  automobiles emit a
greater percentage of pollution in the first few minutes of
operation.  Even an HEV, with its reliance on the gas engine to
charge its battery, will commonly trigger the start-up of its gas
engine  for the first use of the day. On the other hand, a PHEV
will rely on its electric motor almost exclusively for those
shorter trips. Thus, the PHEV, especially on shorter-range trips,
has the potential to increase  the fuel efficiency of HEVs by 50%
or more, while virtually eliminating the cold engine emission
factor. PHEVs would therefore be an effective strategy for
reducing both GHGs and criteria pollutants.   Recognizing the
importance of PHEV technology, Google is in the process of
converting its business fleet from HEVs to PHEVs.   This is  being
accomplished by the installation of an after-market Battery Range
Extender Module that results in double to triple the fuel
efficiency of the conventional hybrids.  Another private company
has developed an  ultra-capacitor component that is designed to
enable smaller battery packs to provide outsized acceleration in
PHEVs.  The company is currently shopping for an OEM to
mass-produce a PHEV which  incorporates the innovation.  To help
both OEMs and PHEV conversion companies produce  PHEVs, ARB can
create a program and incentives to encourage the conversion of the
100,000 HEVs that are currently in use on California highways. 
This would have immediate results in better fuel economy,  fewer
visits to gas station, lower fuel costs, a longer all-electric
drive range, and a significant reduction in all types of
emissions.   To jumpstart the development and adoption of this new
technology, ARB  could mandate that all purchases and leases of
state fleet vehicles of the appropriate class and size be PHEVs or
ZEVs.  This would create a working example that would incentivize
manufacturers to fine-tune the technologies, increase production
of units, and stabilize pricing and availability.  Conversions
alone, however, will not reach AB 32 GHG goals.  ARB can also
design requirements and incentives for OEMs to  ramp-up factory
production of PHEVs and EVs, and to provide reasonable service
warranties for HEVs that have been converted to PHEVs.   The
economic, political, social and health issues caused by reliance
on conventional fuel consumption in the Transportation sector will
 increasingly crossover into the Utilities sector as transportation
becomes electrified.  Clearly, a BEV that is charged from
coal-fired generators will be responsible for more ‘upstream’ GHG
emissions than one  powered by solar- or wind-produced
electricity.  However, it is notable that California only gets
about 16% of its electric power from coal, far less than the US
average of 50% (or more), and further reductions in  the share of
coal power in this state are likely—especially given the legal
framework that now regulates carbon emissions from coal plants
delivering power to California’s electric grid. This means that
California  is in one of the best positions to realize the
benefits of electrification of transportation.   Possibly the
greatest challenge facing ARB is to envision and co-ordinate
programs for all of the different sectors with state and local
agencies.  One innovative program in the Utilities sector --
Community  Choice Aggregation -- has the potential to create a
network of localities for accelerating the statewide adoption of
renewable sources of electrical generation, while also offering
unique opportunities for  electrification of vehicles.  

Utilities Sector:  Community Choice Aggregation (CCA) and 
Increased Use of Renewable Energy  Summary: To date, approximately
forty California local  governments are in the process of
considering and/or implementing Community Choice Aggregation
(CCA). CCAs, like Investor-Owned Utilities (IOUs), participate in
the statewide mandate for reaching 20% renewables by 2010.
However, most of the California CCAs have adopted goals to double,
triple or quadruple the renewables percentages currently deployed
by the IOUs.   A major intent of CCA legislation is to encourage
investment in, and build-out of, renewable energy production
facilities in each  locality throughout the state. CCAs provide
consumers with administrative channels which fiscally support
alternatives to conventional fuels, potentially jumpstarting the
funding necessary  to make cleaner (and ultimately less costly)
alternatives economically viable and available to residents and
businesses.

The Expert Advisory Panel to ARB has singled out local governments
as responsible entities for implementing greenhouse gas reduction
in the energy sector. However, the Panel Report failed to include
one of the  most powerful tools the state has created for enabling
local governments to have a voice in energy policy decisions:
Community Choice. Community Choice is strongly supported by the
Sierra Club,  particularly because it can help reduce the
environmental footprint of our energy supply.   California has
joined the states of Ohio, Massachusetts, New Jersey, and Rhode
Island in establishing a Community Choice law (AB 117, 2002).  The
legislation authorizes local governments (cities, counties, or  a
group of cities and/or counties) to combine the buying power of
all customers in their jurisdiction for purchasing electricity in
an entity called a Community Choice Aggregation, or “CCA”.  This
is done, in order to  achieve, among other benefits, local control
over energy policy decisions, more customer friendly services, and
an expanding percentage of renewables in their local portfolios. 
To date,  approximately forty California local governments are in
the process of considering and/or implementing CCAs.    In the CCA
structure, local entities do not secure power for themselves, but
rather sign contracts with state licensed electric service
providers who are experienced in power purchasing. Transmission
and distribution wires continue to be owned and operated by the
local utility company. The utility company also retains
responsibility for billing consumers, and may collect a Cost
Responsibility Surcharge from all  customers who join the CCAs.
This surcharge is designed to include the same expenses that are
paid by all other customers who continue to receive service from
the utility company. The surcharge is not  permanent, and most of
the amount will expire by 2012.  CCAs, like Investor-Owned
Utilities (IOUs), participate in the  statewide mandate for
reaching 20% renewables by 2010. However, most California CCAs
have adopted goals to double, triple or quadruple the renewables
percentages currently deployed by the  IOUs.  When a community
forms a CCA, the IOU which services the community retains its
renewables portfolio, including the share that formerly was used
to supply the departing customers. This means that  forming a CCA
actually benefits the utility company by increasing its percentage
share of renewable energy, since the same amount of renewable
energy now serves the remaining customers who have not  switched
to CCA.  For this reason it is important to understand that any
renewable supply for the CCA should be measured from a correct
baseline. In general, the renewable power supply that a CCA
contracts  with or builds itself will represent an increase in
renewable power to the state.  This is certainly the case if the
CCA finances and builds its own new renewable energy supply.   A
major intent of CCA legislation is to encourage investment in, and
build-out of, renewable energy production facilities in each
locality  throughout the state.  This can be accomplished by the
CCA providing financing and/or guaranteeing long-term purchase
contracts to prospective builders of renewable energy facilities.
Use of public  financing, such as low-interest municipal bonds,
can significantly reduce the cost of renewable energy and help to
make renewables competitive with conventional power supplies. Bond
financing can cut the long-term  cost of renewable energy by 5 % to
50%. (see California Energy Commission, Comparative Costs of
California Central Station Electricity Generation Technologies
(2007 Update) - FINAL STAFF distribution wires continue to be
owned and operated by the local utility company. The utility
company also retains responsibility for billing consumers, and may
collect a Cost Responsibility Surcharge from all  customers who
join the CCAs. This surcharge is designed to include the same
expenses that are paid by all other customers who continue to
receive service from the utility company. The surcharge is not 
permanent, and most of the amount will expire by 2012.  CCAs, like
Investor-Owned Utilities (IOUs), participate in the  statewide
mandate for reaching 20% renewables by 2010. However, most
California CCAs have adopted goals to double, triple or quadruple
the renewables percentages currently deployed by the  IOUs.  When
a community forms a CCA, the IOU which services the community
retains its renewables portfolio, including the share that
formerly was used to supply the departing customers. This means
that  forming a CCA actually benefits the utility company by
increasing its percentage share of renewable energy, since the
same amount of renewable energy now serves the remaining customers
who have not  switched to CCA.  For this reason it is important to
understand that any renewable supply for the CCA should be
measured from a correct baseline. In general, the renewable power
supply that a CCA contracts  with or builds itself will represent
an increase in renewable power to the state.  This is certainly
the case if the CCA finances and builds its own new renewable
energy supply.   A major intent of CCA legislation is to encourage
investment in, and build-out of, renewable energy production
facilities in each locality  throughout the state.  This can be
accomplished by the CCA providing financing and/or guaranteeing
long-term purchase contracts to prospective builders of renewable
energy facilities. Use of public  financing, such as low-interest
municipal bonds, can significantly reduce the cost of renewable
energy and help to make renewables competitive with conventional
power supplies. Bond financing can cut the long-term  cost of
renewable energy by 5 % to 50%. (see California Energy Commission,
Comparative Costs of California Central Station Electricity
Generation Technologies (2007 Update) - FINAL STAFF REPORT,
CEC-200-2007-011-SF.)  The local nature of CCA programs enables
each entity to tailor their  energy supply according to the
particular geographical strengths and resources.  For example,
portfolios can be assembled from power generation by solar
photovoltaics, solar thermal, wind, geothermal,  hydroelectric,
tides and waves, ocean thermal, and biomass/methane combustion. By
providing local communities with administrative power to
financially support alternatives to conventional fuels, CCAs can 
jumpstart the funding necessary to make cleaner alternatives
economically viable and available to residents and businesses.  
Traditionally, the California Public Utility Commission (CPUC) has
regulated the IOUs across the state. The three major IOUs— Pacific,
Gas, and Electric (PG&E), Southern California Edison (Edison), and 
San Diego Gas and Electric (SDG&E)— have expressed a laundry list
of concerns about CCA implementation, and in some instances, have
actively sought to impede the development of CCAs in their service
 areas.  For example, PG&E is currently involved in legal disputes
with the San Joaquin Valley Power Authority -- the governing body
for a CCA comprised of 12 municipalities in the Kings River
Conservation  District.  While some IOU-CCA disputes involve
control over local power generating sources, others arise due to
the ‘risk adverse’ nature of the IOU corporate structure in
general.  IOUs are simultaneously  responsible to their
shareholders for maintaining economic profits and to their
customers for maintaining utility services.  These dual
responsibilities have the effect of creating a vested interest in
preserving  existing infrastructure retained by the utility— the
transmission and distribution system and nuclear power plants. 
Renewable and natural gas power plants have nearly all been
divested under the market  restructuring of the 1990s, and utility
companies are not given a profit for purchasing power from these
sources. Utility companies often oppose new technologies or market
structures which they perceive as  disruptive to the status quo,
and this has been a source of conflict over implementation of a
wide range of programs, including CCA. In addition to utility
companies fighting CCA, there are other important market barriers
to implementing clean energy. The IOUs and the CPUC have used a
‘Least-Cost/Best-fit’ criterion for evaluating contract  needs,
which often stacks the deck against renewable power. This method
evaluates ‘one contract at a time’ under a competitive
solicitation process to determine which power generation is the
least  costly for fulfilling utility service needs.  That type of
evaluation is incompatible with efforts to transform the existing
energy supplies for at least three reasons:  1) A
contract-by-contract approach is too  fragmented to successfully
redesign the entire electric system as a renewable system, 2) The
“Best-Fit” criterion means that renewable supplies must fit in to
a system that is designed around conventional  power sources, not
for integrating renewable energy, and 3) It requires all renewable
energy to compete with forecasted prices for natural gas power
plants. This last point has multiple problems: renewable energy 
often provides greater service than it is given credit for,
particularly for environmental protection, and natural gas price
forecasts have been notoriously low, which understates the
price-risk protection that  renewables provide.  Actually, the
IOUs’ current 12-13% renewables portfolios were built  almost
entirely in the 1970s and 1980s when state and federal tax credits
were in place.  Since the inception of AB 107, the IOUs have hardly
increased the percentage of renewable energy in the state. 
Instead, we have seen a massive build-out of new natural gas fired
power plants, exceeding 15,000 megawatts.  Furthermore, five years
into the renewables program, no penalty has ever been assessed for
 non-compliance, even though IOUs have consistently fallen short on
mandates. The loopholes entertained by the CPUC are too broad and
lax, and the penalty assessment cap -- were it to be enforced --
of $25  million per utility represents a meager fine in comparison
with billions in yearly revenues and profits.  One of the most
important roles that ARB could play in this realm is to recommend
restructuring of state law to  allow a price structure that is
more favorable to renewable energy, such as “feed-in tariffs” that
insure full compensation for cost of renewable energy plus a fair
rate of profit (discussed more fully under Market-Based Incentives
below).  Given the fact that the electric utilities account for
over 20% of the  state’s total GHG emissions, it is imperative for
ARB to facilitate a restructuring of the state’s reliance on
conventional fuels for its electricity generation.  The current
impasse among the IOUs and the  nascent CCAs could be ameliorated
by new ARB regulations that formalize the connection between the
growth of CCAs and the fulfillment of the AB 32 mission. 
Participation in the CCA initiatives  provide venues for the IOUs
to compete in achieving higher levels of renewable energy without
bearing all of the planning burdens for new infrastructure, and
without being outpaced by consumer demand for  renewable sources
of power generation.   ARB can provide a ‘voice of reason’ in this
arena and can bypass  traditional obstacles to achieving meaningful
progress in this sector.  For example, ARB can play a role in
forging fair rules and accommodations for co-generation and
distributed generation of renewables within CCA  portfolios.  In
its 2007 Integrated Energy Policy Report, the California Energy
Commission (CEC) declares:  “Distributed generation and combined
heat and power, regardless of size or interconnection voltage, 
are valuable resource options for California.  Combined heat and
power, in particular, offers low levels of greenhouse gas
emissions for electricity generation, taking advantage of fuel
that is already being used  for other purposes. “ As the CEC has
pointed out, it will be important to create rules that are not
discriminatory against cogeneration, as these facilities combine
what would otherwise be two emission sources into  one location. A
narrow view might otherwise make it appear as though the
cogenerator were increasing emissions on the site, when in fact
they are substantially reducing emissions overall for the energy
sector in a  given area. Clearly all such facilities must meet all
applicable air quality standards, and special attention should be
paid not to increase criteria pollutants in heavily impacted
areas.   Distributed generation, such as local solar, wind or fuel
cells, can also play an important role in helping to meet local
capacity requirements.  (See:
http://www.energy.ca.gov/2007publications/CEC-100-2007-008/CEC-100-2007-008-CMF.PDF).
 Traditionally, distributed generation has been penalized with
‘standby reservation’ charges, while  combined heat and power has
been taxed by non-bypassable charges. This is just one area where
ARB could assist in removing barriers to adoption of more
favorable clean energy portfolios by CCAs. Unlike  utility
companies, CCAs are groups of customers. This is important since
cogeneration and distributed generators allow customers to
generate their own power, and thus reduce usage of utility owned 
assets. Rewarding clean local and onsite power supplies would thus
be a stabilizing influence to the emerging clean power generation
market, and substantially contribute toward a statewide reduction
in GHG  emissions.    

Waste Sector:  Zero Waste Policies and Landfill/Composting
Regulations   Summary:  Sierra Club California endorses the Zero
Waste Hierarchy – Reduce, Reuse, Recycle, Compost, Discard – as
the model to accomplish CIWMB’s Zero Waste policies.  We urge ARB 
to implement ETAAC’s recommendations for ‘lifecycle tracking’ of
manufactured products, for the reduction of landfill waste by
requiring recycling in the commercial sector, and for the 
construction of discrete composting facilities to separate
greenwaste from landfill waste.  Furthermore, in order to ensure
the continued viability of the composting industry in California, 
proper co-ordination among state and local agencies is essential
for achieving reductions in VOC and GHG emissions in concert,
attendant to rules and regulations which adopt economically- and 
technologically-sound solutions.   

California is a US leader in recycling programs at both the state
and  local levels.  The California Integrated Waste Management
Board (CIWMB) is promoting a ‘Zero Waste California’ program at
the state level that redefines the concept of waste to include the
assurance that products are designed and manufactured with the
potential to be repaired, reused, or recycled: “In the past, waste
was considered a natural by-product of our culture. Now, it is time
to recognize that  proper resource management, not waste
management, is at the heart of reducing waste sent to landfills...
For years, we have been throwing valuable resources away—the same
resources we will inevitably need in  the future—all in the name
of consumer and manufacturer convenience”
(http://www.zerowaste.ca.gov/WhatIs.htm ).     

On the local level, notable California city mayors have signed the
United Nations Urban Environmental Accords (2005), which address
seven environmental areas common to all the world’s large cities:
water,  energy, waste, urban design, transportation, urban nature,
and environmental health.  To reduce the waste stream in their
cities, these timetables have been established:  1) Achieve Zero
Waste to landfills  and incinerators by 2040; 2) Adopt citywide
laws that reduce the use of disposable, toxic, or non-renewable
products by at least 50% by 2012; and 3) Implement ‘user-friendly’
recycling and composting programs,  with the goal of reducing solid
waste disposal to landfills and incineration by 20% per capita by
2012.  (See: http://www.cameronforcolumbia.com/ 
Downloads/Documents/UNEnvironmentalAccords.pdf ).  The CIWMB
emphasizes that Zero Waste will only succeed if local governments,
businesses, industry, and private citizens embrace coherent
resource  management programs.  The Sierra Club wholeheartedly
embraces Zero Waste policies, and agrees with CIWMB that the two
major points for scrutiny of consumable products are at the
beginning and end  of their lifecycles, i.e., at the points of
manufacture and disposal.   

Zero Waste is based on the concept of Extended Producer 
Responsibility (EPR).  EPR requires that manufacturers, retailers,
and consumers share responsibility for minimizing a product's
environmental impact (e.g. ‘embedded or upstream’ emissions)
throughout all stages  of the products' lifecycle.  EPR is also
called ‘product stewardship’.  At the birth of a product, Zero
Waste requires that materials, containers, and packaging be
cleanly manufactured, without contributing to GHG and criteria air
pollutant emissions.  At the sale and consumption phases, Zero
Waste privileges those products that are reusable and have been
manufactured locally.  At the end of the cycle, Zero Waste 
creates a hierarchy of actions which emphasizes reusing,
recycling, and composting in descending order, and resorts to the
discarding of materials as a last resort (see 
http://www.sierraclub.org/commitees/zerowaste/policy.pdf ).  

The 2008 ETAAC Report supports the concept of ‘lifecycle tracking’
 as one of a “suite of emissions reduction protocols for recycling”
in the commercial sector, along with the use of secondary or
post-consumer materials in manufacturing, and the separation of
cardboard and paper  from other commercial waste.  The Report
suggests that any firm generating 4 or more cubic yards of waste
per week be required to “implement a recycling program that is
appropriate for that kind of  business.”   Lifecycle initiatives
directly address the issue of embedded or upstream GHG emissions
which are present in every manufactured product.  Likewise, the
Zero Waste Hierarchy recognizes that the  recycling of
manufactured products has the effect of offsetting embedded
emissions by extending the useful lifespan of the materials, while
simultaneously eliminating the emissions that would have been 
attendant to the new manufacture of similar materials.  

Sierra Club California urges CIWMB and ARB to implement regulatory
 mechanisms that reverse business-as-usual practices which have led
to steady increases in GHG emissions in the industrial sector
(Manufacturing processes account for 18% of total GHG emissions 
statewide).  The state’s 92 million tons of annual waste can be
dramatically reduced by instituting lifecycle tracking of GHG
emissions for all of the major mass-produced commodities. 
Manufacturers who  meet a certain of volume of sales and/or exceed
GHG emissions thresholds would be required to produce a lifecycle
environmental impact statement.  The statement would include a
plan for how the  waste impact would be mitigated. Until the
present, businesses have calculated their costs without pricing
the impact of their actions on the environment.  In effect, the
benefits have been privatized and the costs have been socialized. 
A reformulation of waste policies under AB 32 goals provides an
opportunity for the business and industrial communities to work
together with government and consumers to fairly  distribute costs
associated with reducing current GHG emissions from manufacturing
processes and landfill facilities.   

ARB has wisely recognized that improved landfill methane capture
qualifies as an ‘early action measure’ under AB 32, and has
expeditiously co-authored draft regulations with CIWMB to limit
the  volume of surface methane emissions from municipal solid
waste (MSW) landfills to 200 ppmv, effected by requiring the
installation of gas collection and control systems for maintaining
those limits. At the  same time, ARB also recognizes that these
measures are transitional in nature, since the co-mixing of
organic materials and non-recyclable materials is a sub-optimal
practice slated to be discontinued as Zero  Waste policies mature.
Towards this goal, ARB’s staff is currently working with the San
Joaquin Valley Unified Air Pollution Control District and the
CIWMB on two fronts: 1) to resolve conflicting studies  measuring
VOC emissions from composting facilities, and 2) to establish
regulations that will cohesively address the Air District’s
concern with VOC emissions from composting facilities and the 
IWMB’s focus on reducing GHG emissions through increased build-out
of composting facilities statewide.   

Establishing composting standards is an area where co-ordination
among state and local agencies is essential for achieving
reductions of air pollutants and emissions in concert, and Sierra
Club appreciates the  Air Resources Board efforts in working
toward a comprehensive model.  Sierra Club urges ARB to continue
its oversight of the Waste sector by endorsing the cessation of
diversion credits for the use of  greenwaste as alternative daily
cover, and by endorsing assessment fees for dumping compostable
waste in landfills. Most importantly, ARB should advocate the
separation of compostable organics (exclusive of  sewage sludge or
bio-solids) from materials deposited in landfills. In addition,
assessments on carbon emissions, whether in the form of taxes,
fees or auction revenues, should be used to subsidize technology 
upgrades to compost facilities so that they can comply with
regulations for air quality and GHGs and also remain in business. 
 

To assist ARB and CIWMB in rethinking the current design of waste
facilities, Sierra Club proposes the statewide installation of
‘Resource Recovery Parks’ -- locations that centralize and
integrate facilities for  reusing, recycling, composting, and
discarding materials.  Such parks can include repair services,
retail sales of reclaimed products and landscaping supplies,
organically composted gardens, educational tours,  and public
amenities.  The regional environmental park operated by the
Monterey Regional Waste Management District in the city of Marina
provides a model for this idea.  The Park is comprised of three
areas: 1)  a 315 acre landfill site that houses construction and
demolition recycling operations, composting facilities, and a
soils-blending facility; 2) a 126 acre buffer zone of Salinas
River floodplain; and 3) a 20 acre site that  houses
administration and maintenance buildings, a scale-house, a public
drop-off recycling station, retail ‘resale and materials recovery’
businesses and stores, a landfill gas power project, and a
household  hazardous waste collection facility (see
http://www.sierraclub.org/committees/zerowaste).    

The Waste sector is connected to all other sectors in the sense
that it is the recipient of their discarded or ‘used-up’
materials.  An innovative method of rethinking Waste’s connection
to our daily activities would  be for ARB to partner with other
agencies in developing demonstration projects for employing
composted greenwaste and recycled products in a variety of
state-and city-sponsored activities.  The use of compost can 
benefit agricultural operations, landscaping businesses, and
public parks and roadway plantings, which all contribute to GHG
emissions by their reliance on pesticides and synthetic
fertilizers.  Such projects can help  attain AB 32 goals for
achieving Zero Waste by transforming discarded materials into
useful resources. 

Market-Based Incentives  

Feed-in Tariffs (FiTs)   

Feed-in Tariffs (FiTs) have been used in over 37 countries around
the world for accelerating the adoption of renewable electricity
generation,  and for stabilizing the market prices of new
technologies.  A FiT establishes a price paid for a particular
source of renewable energy -- such as wind, solar, or geothermal
-- that is based on the actual cost of  producing a kilowatt-hour
(kWh) of electricity from that power source.  This method is
distinguished from California’s system of using a ‘market price
referent’, which evaluates each renewable energy contract based 
upon the expected future price of natural gas base-load
generation.  FiT implementation frequently obligates a utility
company to buy renewable energy at rates higher than they might
pay for a kWh of electricity  generated by conventional fuels,
often at rates based on the cost of production.    Any extra
energy costs are distributed among all customers.  In Germany, for
example, it is commonly said that the added monthly fee on
consumers’ bills is comparable to the cost of a loaf of bread. US
and  worldwide polls have shown that most consumers are willing to
pay more for electricity generated by renewable power sources. 
FiTs encourage the stabilization of energy prices because
renewables’  producers are guaranteed a 10, 15, or 20 year fixed
price per kWh.  This structure enables manufacturers to predict
demand and to allocate investment resources with confidence.  
Prices for new contracts may  be gradually lowered to encourage
efficiencies in new renewable energy technologies, or they may be
adjusted upward if the prices established are not sufficient to
stimulate the market.    In February 2008, the CPUC approved a FiT
to support the development of up to 480 megawatts (MW) of renewable
generating  capacity from small facilities throughout California. 
The PUC regulation targets wastewater treatment facilities and
livestock operations that have 
upgrades to compost facilities so that they can comply with
regulations for air quality and GHGs and also remain in business. 
 To assist ARB and CIWMB in rethinking the current design of waste
facilities, Sierra Club proposes the statewide installation of
‘Resource Recovery Parks’ -- locations that centralize and
integrate facilities for  reusing, recycling, composting, and
discarding materials.  Such parks can include repair services,
retail sales of reclaimed products and landscaping supplies,
organically composted gardens, educational tours,  and public
amenities.  The regional environmental park operated by the
Monterey Regional Waste Management District in the city of Marina
provides a model for this idea.  The Park is comprised of three
areas: 1)  a 315 acre landfill site that houses construction and
demolition recycling operations, composting facilities, and a
soils-blending facility; 2) a 126 acre buffer zone of Salinas
River floodplain; and 3) a 20 acre site that  houses
administration and maintenance buildings, a scale-house, a public
drop-off recycling station, retail ‘resale and materials recovery’
businesses and stores, a landfill gas power project, and a
household  hazardous waste collection facility (see
http://www.sierraclub.org/committees/zerowaste).    

The Waste sector is connected to all other sectors in the sense
that it is the recipient of their discarded or ‘used-up’
materials.  An innovative method of rethinking Waste’s connection
to our daily activities would  be for ARB to partner with other
agencies in developing demonstration projects for employing
composted greenwaste and recycled products in a variety of
state-and city-sponsored activities.  The use of compost can 
benefit agricultural operations, landscaping businesses, and
public parks and roadway plantings, which all contribute to GHG
emissions by their reliance on pesticides and synthetic
fertilizers.  Such projects can help  attain AB 32 goals for
achieving Zero Waste by transforming discarded materials into
useful resources. access to substantial biogas (methane
combustion) resources.  However, the sale prices set by the tariff
may be too low, and the 480 MW limit restricts the ability of the
current FiT to significantly help  achieve the Renewables
Portfolio Standard (RPS) goals.  The current FiT also excludes
important sources of renewable energy such as solar and wind
energy.  Without an approved FiT, investor-owned utilities  (IOUs)
have a disincentive to unilaterally offer a standard contract rate
to renewable energy generators.  Countries with successful FiTs
have required utility companies to offer standard rates until the
national  renewable energy goal is met.  California should model
any FiTs it may develop upon countries that have achieved
significant growth of renewables by implementing a feed-in tariff.
   The FiT is an efficient market-based tool to implement a
Renewable Portfolio Standard.  In particular, it avoids much of
the complexity, risk  and delay that renewable developers face
under the current regulatory structure, and that have created a
formidable barrier to new projects. A FiT in California should be
tied to meeting the state’s RPS goals.  One  option would be to
require utility companies to participate until their RPS
obligations have been met, or in the alternative, they should be
penalized for non-compliance with AB 107 mandates.  A third 
alternative, following the German model, is to pool the
incremental costs of renewable energy generation on a statewide
basis, and apportion the costs to IOUs based on actual costs paid
to generators.  Under this  alternative, IOUs would offer
contracts at the FiT rate until the state RPS goal is met.  This
is a clear area where CARB’s ability to take leadership by
researching and recommending rational and necessary  solutions is
needed to overcome institutional prejudices against adopting
cleaner technologies for power generation.    

Cap-and-Auction and Offsets   

The scoping plan should adhere to the legislative requirements in
AB  32 mandating that the Board study the potential impacts on
community air quality of any market-based compliance mechanisms,
before adopting any such mechanism. Should California adopt a
mechanism that creates emission allowances, it is vital that it
require that all old and new sources of greenhouse gases pay for
the privilege of using limited carbon sinks. Give-away carbon
permit schemes, in which current  emitters are permitted to turn
their pollution into economically valuable rights, would violate
this principle.   

If CARB establishes a market for carbon emissions, after following
the review process required by AB 32, allowances or permits should
be auctioned.  The auctioning of permits allows for the reduction
of  permits, and emissions, over time, so the market adjusts to
reflect the true cost of greenhouse gas pollution, Such a
mechanism for pricing the carbon released into the atmosphere is
essential if we are to raise   investment funds to construct the
new clean energy economy in California, provide investment capital
to guarantee that new technologies are available to our existing
infrastructure, and make  certain that the effects of re-pricing
carbon fuels are not felt disproportionately by working families
and small businesses. We believe that AB 32 has given ARB the
authority to establish an auction system.   

Freely issuing emission permits to industry based on historic
performance would create a trading system with inherent flaws.
Some  industries may use such a system to guide them in making
rational investments that achieve a beneficial social outcome. For
others, however, it would provide a perverse incentive to shut down
existing  California plant capacity and either relocate in other
states or distant parts of the world. An auction system is capable
of raising funds that can provide meaningful incentives for
reinvestment in domestic energyefficient industries. This could
strongly counteract any potential flight of industry from the
state, and would help assure the immediate goal of protecting the
domestic economy.   

Furthermore, Sierra Club will oppose any market system that would
relieve carbon polluters from paying their fair share of the costs
of the  carbon they emit in exchange for "offsets," either
internationally for CO2 emissions, or domestically for activities
designed to enhance carbon sinks, like tree planting.  While
government and private support for programs that increase soil
carbon content and reforestation are highly desirable, it is
impossible to retain the enforceability and effectiveness of a
carbon pollution trading scheme if it is combined with efforts to 
preserve and enhance carbon sinks. We need both 80% reductions in
CO2 emissions and strong programs to enhance carbon sinks; we
should not “trade” them off against each other.  In addition,
there are  verification and “additionality” problems that severely
impact the enforceability and validity of a cap-and-trade or offset
system.  By contrast, an auction without offsets allows the market
to reflect the cost  of carbon pollution while providing greater
assurance of achieving greenhouse gas emission reduction goals.   


If market mechanisms are used, they should be designed so that
they contribute to verifiable and enforceable CO2 reductions and
work in harmony with other components of the climate change
strategy,  especially standards and incentives for promoting
efficiency, conservation and renewable energy. Funds raised
through the auction of carbon allowances should be used for public
purposes such as energy  efficiency, promotion of renewable energy,
mitigation of ratepayer impacts, needed infrastructure in impacted
communities, and job training opportunities in renewable energy
for individuals working in the fossilfuel  industry.  

Forests can play an important role in reducing the impact of
global  warming, since approximately half the weight of a tree is
carbon.  Growing larger, older trees is helpful because they
capture and store more carbon.  Conversely, converting forests to
other uses, through  sprawl and development, eliminates carbon
storage opportunities now and into the future, and should be
discouraged.  Although forests will have a role in addressing
global warming, they have many values  besides carbon storage, and
need to be managed in a way that promotes healthy natural systems.
Above all, the ability of forests to store carbon should not
become a justification for higher emissions of  air pollution.  

Allowances and auction revenues should be used to accelerate
deployment of clean energy technologies, with priority given to
the cleanest, cheapest, safest, and fastest means of reducing
emissions.  On the other hand, the Sierra Club strongly believes
that a carbon pollution  auction scheme is by no means the only
option for reducing carbon emissions. At best it should be
considered only one possible tool among many, and we urge ARB to
remain open to alternative compliance  options such as direct
regulation with fines for non-compliance, or direct charges like
fees or carbon taxes. 
 
 Conclusion  

ARB’s mandate to author a Scoping Plan for AB 32 gives it
wideranging authority to take wide-ranging laws and integrate
these in a constructive way, to work collaboratively with local
air quality districts and CCAs, and to coordinate state programs
to quickly achieve  quantifiable results. Where these are not
sufficient, ARB can use its key role under AB 32 to help the
legislature and state regulatory bodies to move to more effective
policies. ARB is currently in a position—of truly  global
significance—to enact measures which can lend a greater degree of
predictability and stability to this emergent paradigm.  Sierra
Club California recognizes the magnitude of the responsibilities
laid upon the  Air Resources Board, and is willing to work with
staff and assist in any way we can.  Thank you for this
opportunity to participate in the Scoping Plan process.  

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2008-07-30 16:42:44



If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.


Board Comments Home

preload