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Comment 103 for 2030 Target Scoping Plan Discussion Draft (sp2030disc-dec16-ws) - 1st Workshop.
First Name: Nicole
Last Name: Vermilion
Email Address: nvermilion@placeworks.com
Affiliation: AEP Climate Change Committee
Subject: AEP Climate Change Committee Comments on the Discussion Draft 2030 Target Scoping Plan
Comment:
On behalf of the Association of Environmental Professionals (AEP), Climate Change Committee, we appreciate the opportunity to provide comments on the Discussion Draft, 2030 Target Scoping Plan Update. This supplements our comments previously provided to CARB on June 8, 2016 on the 2030 Target Scoping Plan Concept Paper and comments provided on November 21,2016 on the November 7, 2016, Public Workshop on the 2030 Target Scoping Plan Update: GHG Policy Scenarios, Natural & Working Lands, and Public Health Analysis. AEP is a non-profit organization of California’s environmental professionals. AEP’s Climate Change Committee (Committee) members are actively involved in supporting California cities and counties in the evaluation of greenhouse gas (GHG) emissions impacts for new development subject to the California Environmental Quality Act (CEQA), preparing communitywide GHG emissions inventories and forecasts and developing and implementing Climate Action Plans (CAPs). The update to the Scoping Plan to address the 2030 target in Senate Bill 32 (SB 32) and Executive Order B-30-15 is of great interest to the Committee and our CEQA and climate action planning work with California cities and counties, especially as it relates to local target setting. The Committee supports CARB in its challenging work to establish a working framework for achieving the next milestone in GHG reductions for California. The Committee published two white papers in 2015 and 2016 (http://califaep.org/climate-change) that examine in detail the challenges for both CEQA practice and local climate action planning related to post-2020 GHG reduction targets. Many of us are already engage in developing local CAPs that include post-2020 GHG reduction goals. As a result, we are concerned that the proposed policies for local plan level goals extend too far into local policy decision-making by specifically identifying a local target for climate action plans. The committee is also concerned that establishing a community-wide goal for 2050 will immediately shift the focus of CEQA and Climate Action Plan target setting to the 2050 goal, for which no clear path is certain for local governments and which will result in an ineffective and speculative focus on 2050 at the expense of the real and urgent necessity to focus on meeting the ambitious 2030 goal. Moreover, delving into project-level CEQA thresholds is better left to local air districts and counties since they are attuned to local-regional constraints. Therefore, our recommendation is to remove the section regarding Local Plan-Level GHG Reduction Goals and the section regarding Project-Level GHG Reduction Actions and Thresholds from the 2030 Target Scoping Plan Update.
Attachment: www.arb.ca.gov/lists/com-attach/105-sp2030disc-dec16-ws-VTRdPgBxBQkHYlU6.pdf
Original File Name: AEP_Comments_ARB_DD2030TSP.pdf
Date and Time Comment Was Submitted: 2016-12-16 15:32:33
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