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Comment 15 for Industry Comments for the GHG Scoping Plan (sp-industry-ws) - 1st Workshop.
First Name: Keith
Last Name: Adams
Email Address: adamskb@airproducts.com
Affiliation: Air Products and Chemicals
Subject: Industry Sector Comments
Comment:
Excerpts from general comments letter regarding: 1) Energy Efficiency Audits Air Products agrees that continued focus on energy efficiency is the GHG reduction strategy with the most positive economic impact. In requiring energy efficiency audits, CARB should develop guidelines and allow those industries with the technical capability to perform self-audits. Regardless of who conducts such audits, CARB must ensure the protection of Confidential Business Information likely to be revealed through the audit process. CARB must also define the criteria for determining “cost effectiveness” when considering rule provisions or permit conditions to prescribe such measures, taking into account differences between industries and competitive conditions of individual facilities. 2) Sector-Based Measures for Refineries/Oil and Gas Production Air Products supports efforts to provide regulatory incentives for achieving continued process efficiency in refinery operations. We encourage CARB to consider the impact third-party support facilities/processes contribute to overall refinery efficiency. Such efficiency improvements will also yield reductions in criteria pollutants in particularly challenged air sheds.
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Date and Time Comment Was Submitted: 2008-08-01 15:58:38
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