Comment Log Display

LACSD offers the following comments on the discussion concerning
Industry Strategies in the Draft Scoping Plan:


1.	Page C-102: We question the value of energy efficiency and
co-benefits audits for large industrial sources.  As stated
previously, given control measure MCS-01 in SCAQMD’s 2007 AQMP,
most stationary combustion sources in the South Coast will be
forced to BACT levels so there will be little margin left for
improvement.  To conduct an audit specifically to find co-benefits
is not appropriate as the focus of AB 32 is greenhouse gas
reduction.

2.	Page C-115: In the South Coast, boiler efficiency may actually
drop and GHGs increase as result of control measure MCS-01 which,
in driving boiler NOx lower, is also lowering boiler efficiency
thereby increasing the amount of fuel that needs to be burned to
deliver the same usable output.  See the Environmental Assessment
for Rule 1146.  The goal of increasing boiler efficiency and
thereby reducing GHG emissions is thwarted by AQMPs that are
solely focused on criteria pollutant reduction.  CARB needs to be
the arbitrator in these situations.

23.	Page C-116: In the South Coast, it is difficult to install
stationary internal combustion engines as prime power.  We are
also concerned about across the board electrification of motors as
this reduces the region’s ability to respond to emergencies such as
earthquakes.

Original File Name:

Date and Time Comment Was Submitted: 2008-08-11 14:34:12