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Comments on Industrial sector:

If a new stationary source is above the 'significance threshold'
of 7000 mt CO2e/yr according to CEQA it will need 'mitigation.'  

Since no practical 'mitigation' for CO2 emissions exist besides
efficiency measures, what is the practical value of setting such
'significance levels' since efficiency is it's own incentive?  And
since no single stationary source, no matter how large, will affect
neither global nor california climate, how is this proposed
exercise justified on a scientific or practical basis?  How would
citizens of CA benefit from such a proposal?   

Since 25,000 mt is being used for AB32 inclusion, why is the CEQA
number 7000 mt?  If such a 'significance' measure is to be
considered, 7000 is too low.  Minimum should be in line with AB32
and 25,000 mt.  

Concern is that this proposal adds another level of unnecessary
bureaucracy towards proposed projects with no returned value in
environmental protection.  Potential to impede a project based on
this proposal seems disproportionately large compared to the zero
environmental value it represents.  

The only real effect of this proposal seems to be that it sets up
the potential for holding up worthwhile projects in order to
determine mitigation options that dont exist, while offering zero
environmental benefit in return.  The last thing we need in
california is another level of such academic exercises in
bureaucracy.  

Original File Name:

Date and Time Comment Was Submitted: 2008-11-03 12:34:44