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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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