Comment Log Display

LACSD offers the following comments on the discussion concerning
Local Government Actions and Regional Targets in the Draft Scoping
Plan:


1.	Page C-42: We remain very concerned about how local governments
will allocate responsibility for emissions inventories and
emissions reductions to sources under their jurisdictions without
a significant possibility of double-counting.  This seems to be
particularly the case as the local government source category is
further refined into “community” level analyses.  To examine a
case in point, please provide some explanation of how a regional
local government program meshes with Community Energy and
Community Waste and Recycling concepts articulated on this page. 
Local community actions can also be difficult to calculate from a
credit standpoint in the case of regionally operated waste
disposal facilities.  Energy recovery from these programs needs to
be allocated on some basis to the respective communities under the
regional government umbrella.  Please see our July 18, 2008
comment letter on CCAR’s Local Government Operations Protocol on
this issue.  We think it is very important that CARB abide by its
promise at the very bottom of page 32 of the Draft Scoping Plan
that “ARB will work with local governments to reconcile local
level accounting with state and regional emissions tracking as the
Scoping Plan is implemented.”

2.	C-45: We strongly believe that CARB should input into
California Office of Planning and Research and the Resources
Agency that actions taken in accordance with the Scoping Plan
should be categorically exempt from a GHG analysis component of
any environmental document that is prepared for a project.

3.	C-51: The ARB has stated many times that if push comes to
shove, compliance with health-based criteria pollutant regulations
will have priority over GHG considerations.  With that in mind, we
wonder about the benefit of performing GHG calculations as part
the Subsurface Cleanup Technology discussion that the SWRCB may
implement.  Irrespective of the amount of GHG emitted by RTOs, for
example, the elimination of groundwater contamination will always
take precedence.  The ARB should weigh in on decisions like these
made by other state agencies and at least attempt to streamline or
reduce unnecessary exercises required by other state agencies.