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LACSD offers the following comments on the discussion concerning
Electricity and Natural Gas Strategies in the Draft Scoping
Plan:


1.	Page C-58: The energy sector overlaps with many other GHG
sectors including Local Government, Water, Recycling and Waste
Management, etc.

2.	Page C-62: On-site clean distributed generation (DG) to
accomplish “zero net energy” buildings will be limited in the
South Coast Air Basin because of stringent regulations that in
effect remove reciprocating engines from the DG prime mover list.

3.	Page C-64: Regulation of water efficiency by the CEC is
redundant.

4.	Page C-73: Besides market barriers, significant regulatory
barriers stand in the way of CHP reaching its full market
potential, not the least of which is availability of emission
reduction credits (ERCs) and local AQMPs that make it difficult to
install reciprocating engines running for any length of time during
the day in small CHP systems. The Scoping Plan economic analysis
needs to account for the reality of what “ultra-clean CHP” (Page
C-75) really means.

Original File Name:

Date and Time Comment Was Submitted: 2008-08-11 14:20:23