Comment Log Display

Comments Regarding Local Government Actions and Regional Targets

1.	Voluntary vs. Mandated Approach. It is unclear what ARB’s long
term intent is in terms of mandatory vs. voluntary measures. In
one paragraph ARB encourages local and regional governments to
develop targets to reduce greenhouse gas (GHG) emissions while in
another paragraph ARB states that it will track and account for
the local government actions to reduce GHG emissions. Will cities
be required to track and report GHG emissions and later be
required to meet specific State mandated GHG reductions? ABR
should be clear about its intent for regulations and requirements
for cities in the short and long-term. 

2.	Use of Incentives.  ARB should employ an incentives based
approach for cities to reduce greenhouse gas emissions. Providing
funding to cities to develop regional targets would provide great
incentive for cities to do so. Similar to Proposition 1C in which
the State rewarded smart growth projects, ARB should grant funding
to cities who develop GHG reduction targets and have a climate
change plan to reach their GHG reduction targets. 

3.	The City generally supports tax credits, grants, and loans and
other incentives to assist cities, businesses, and local agencies
that invest in energy efficient equipment, technology, and
programs. However, any carbon fees that ARB is considering must
maximize economic benefits and minimize economic harm. That said,
ARB should set aside a portion of the revenue from the carbon fees
to incentivize local government by:
a.	Providing sustainable community grants to local governments
b.	Funding county-wide and city-wide greenhouse gas inventory
efforts and annual reporting
c.	Granting funds to local jurisdictions based on their efforts to
move their community towards sustainable operations

4.	Distinguish between municipal targets and community targets. 
In general, we agree with the regional approach taken by ARB to
develop regional targets to reduce greenhouse gas emissions,
however, we would ask that ARB distinguish between municipal
targets and community targets. Recognizing that cities have direct
control over municipal facilities and operations and less control
over the community use of energy and transit choices.