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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.

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Date and Time Comment Was Submitted: 2008-07-30 18:20:19



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