Comment Log Display
Below is the comment you selected to display.
Comment 114 for General Comments for the GHG Scoping Plan (sp-general-ws) - 1st Workshop.
First Name: David
Last Name: Assmann
Email Address: David.Assmann@sfgov.org
Affiliation: City and County of San Francisco
Subject: City of San Francisco Comments on AB 32 Draft Scoping Plan
Comment:
The City and County of San Francisco looks forward to partnering with the state to help tackle the greatest environmental challenge of our time. The following is our input into the Draft Scoping Plan. While the Plan emphasizes that local governments and regional government agencies are essential partners in achieving California’s greenhouse gas goals, the only target attached to the local government section is a transportation measure, which vastly understates the contribution that local governments can, should and will bring to the goal of reducing greenhouse gas emissions. Most greenhouse gas emissions are local. Cities now produce seventy-five percent of all the world’s greenhouse gas emissions, so climate solutions that ignore municipalities do so at the planet’s peril. Local governments are on the front lines in fighting the sources of global warming: from revising building codes, promoting energy efficiency, providing recycling and compost services, requiring renewable fuel and energy use, and managing transit systems. Cities too, are responsible for dealing with the impacts of the climate crisis: from providing the first responders in case of extreme weather events to dealing with the day-to-day climate implications for public health, infrastructure, and local economy. More than 852 US cities, including San Francisco, have committed to reduce their greenhouse gas emissions to Kyoto Protocol levels (or beyond). Before we develop an entirely new set of complex regulations to help us implement AB32, we could learn a lot by recycling a few ideas from our past. In the 1980’s, California faced another big environmental crisis: we were running out of space to put our garbage. At that time the state only recycled 11% of all waste and landfills were reaching capacity. In 1989, the State legislated that every city and county achieve a fifty percent recycling rate by 2000 (AB939). This was a truly audacious goal. However, it was the implementation that was precedent setting. All local governments are required to report annually to the State in great detail on the types and quantities of waste diverted from landfill through reduction, recycling, and composting activities, as well as how they are going to meet the targets. Just as with measuring carbon emissions, waste is often a hard thing to track down. The profession of waste auditing and accounting was born. Today every one of California’s 536 local jurisdictions knows how much of their paper, scrap iron, lawn trimmings, bottles and cans, and even building materials is (or is not) being recycled. It is only through this level of detail that we can claim to have a hope of solving multi-source environmental issues from waste to carbon. Any jurisdiction failing to reach the recycling target can be fined $10,000 per day. This threat allowed cities and counties to develop innovative programs like curbside food scrap collection as a way of avoiding hefty fines. Rather than enacting a cooking-cutter regulation that would work for no one, the recycling law allowed each County to adopt a implementation strategy that would work for their communities. This flexibility fostered innovation and efficiency. At the same time, a Recycling Market Development Zone program was created to fuel new businesses wanting to profit from diverting waste from landfills. This recycling law may be the single most effective piece of environmental legislation ever to come of out Sacramento. Today the City and County of San Francisco has been able to work with its residents and businesses to recycle and compost 70% of the waste (we were at 35% in 1990). This same basic legal framework should be applied to the issue of climate change. Under this local CO2 reduction model, counties would be responsible for reducing carbon emissions from building energy, agriculture, manufacturing, and of course waste management. These plans should mandate both a municipal facilities and community wide target for energy, waste reduction and recycling, water and waste water, transportation and community design. Counties would work both locally and regionally to reduce vehicle miles traveled (VMT). The State would continue to have jurisdiction over large emitters like oil refineries, energy utilities, and over developing a low-carbon fuels policy. The State needs to begin by establishing county-level reporting requirements and procedures. Cities and counties will then need financial incentives to develop the critical infrastructure that reducing and measuring carbon emissions will require. Recent reports suggest that building dense transit-oriented urban areas can lead to a forty percent reduction in carbon emissions. Local land-use and zoning policies have therefore become one of the single most important tools in combating climate change. With this newfound power comes the need for accountability. The State should hold counties answerable for meeting targets, and provide rewards to those who achieve more. One of the major problems with the Draft Scoping Plan is that there are no targets for reductions from municipal efforts in recycling, water use or energy, nor are there any targets attached to planning and regional local government efforts. All of these are required elements for a comprehensive plan that would maximize our efforts and resources. While both the Draft Scoping Plan and the appendices reference the vital role that local governments play in community energy, community waste and recycling, community water and wastewater systems, and community design, both the scope and appendices are void of any analysis or recommendations on how local government can and should reduce emissions in these areas. By stating “although not quantified at this time, actions taken by local government are expected to provide significant greenhouse gas reductions” the majority of the efforts that many local governments are already putting into greenhouse gas reductions are essentially being left out of the Draft Scoping plan. To put this into a numerical perspective, San Francisco’s Climate Action Plan, passed in 2002 by the City and County’s Board of Supervisors, set targets of reducing emissions by almost 2 million metric tonnes by 2012. San Francisco accounts for about 2% of the state’s population, yet its reduction target is essentially equal to the local government target set for the entire state. San Francisco, and many other cities, have set targets that are at least double the total target set for local government actions by the state (San Francisco is committed to reducing municipal emissions by 25% by 2017, and 40% by 2025 from 1990 levels). The draft plan and the appendices lump together local and regional governments, and it is not always clear what refers to local government operations, what is directed at local governments only and what applies to regional governments. In preparing the final scoping plan, we recommend that ARB include the following distinct sections under Local Government Actions and Regional Targets: 1. Actions and targets for municipal facilities and operations that are under the direct control of local government, which would include transportation, energy, water and wastewater and waste reduction/recycling. 2. Actions and targets for community wide activities that are directly influenced or under the control of local governments. For example, building codes can directly impact energy use, and greenhouse gas reducing targets should be implemented by local governments. 3. Actions and targets for regional efforts including efforts achieved through regional planning.
Attachment:
Original File Name:
Date and Time Comment Was Submitted: 2008-07-30 18:20:19
If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.