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Comment 40 for General Comments for the GHG Scoping Plan (sp-general-ws) - 1st Workshop.


First Name: Susanne
Last Name: Moser
Email Address: promundi@susannemoser.com
Affiliation:

Subject: evaluation criteria of mitigation measures and mitigation-adaptation link
Comment:
Dear drafters of the scoping report,

I have briefly reviewed your document and am missing two important
considerations:

1) Other than how much a particular measure reduces GHG emissions,
I see no criteria by which to evaluate the proposed actions. A
reduction of GHG BY ANY MEANS should not be acceptable. A systems
perspective will quickly reveal that most actions, technological
fixes, market and policy measures have UNINTENDED consequences.
They could be economic, environmental, social, political or
cultural. I do not see that such considerations are entering your
scoping plan. It seems unacceptable that the state of California
should try to solve one problem by inadvertently introducing
another. Thus, any proposed measure should be evaluated against
not only the impact toward meeting the overall emission reduction
goal, but other ancillary costs, impacts, or benefits. And the
economic cost and benefits should most certainly not be the only
criterion.

2) The IPCC has clearly recognized in its most recent assessment
that there are important interactions between mitigation and
adaptation (see IPCC, 2007, Working Group II, Chapter 20, if I
recall correctly). Some mitigation measures make adaptation more
difficult or easier, while some adaptation measures increase or
help decrease GHG emissions. This report does not recognize this
important interaction. As the state begins adaptation planning, it
seems inconceivable that one effort should not consider how it will
impact another. Well, it's not inconceivable, it's done all the
time, but it SHOULD be avoided. Don't make your work elsewhere
more difficult by ignoring this important connection.

Thank you for improving the report by these considerations.

Sincerely,

S. Moser, Ph.D.
independent Researcher
Santa Cruz, CA

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Date and Time Comment Was Submitted: 2008-07-15 15:22:04



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