Comment Log Display

Dear Dr. Sawyer:

 As a member of three of the signing organizations below (Sierra
Club California, Union of Concerned Scientists and Environment
California) and a supporter of most the other organizations, I
would like to add my name to this letter.

Sincerely,

David Coale

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We represent a broad cross-section of environmental,
conservation,
public health and other public interest organizations who are
strong advocates for an aggressive early action measure strategy
in the implementation of Assembly Bill (AB) 32.  Moving forward
quickly to achieve measurable reductions in global warming
pollution is vital for mitigating potential climate impacts while
the state works toward finalizing its longer term strategy.

 

We acknowledge and appreciate the Administration’s commitment to
successful implementation of AB 32, and believe the process for
meeting the goals of the law is on track. We also are encouraged
to see a measure with such significant GHG emission reduction
potential as the low carbon fuel standard included on your
priority list.

 

Given California’s ongoing challenges in addressing our air
pollution problems, and the opportunities of many GHG reduction
strategies to simultaneously reduce global warming pollution as
well as toxic and criteria pollutants, we encourage you to
thoroughly explore options to expand the early action measures
noted in your draft report released on April 20, 2007.     

 

Specifically, we ask that you consider the following proposals. 

 

Move Heavy Duty Emission Reduction Measures to Group 1 (currently
listed in Group 2)

ARB should analyze potential GHG reductions from every diesel
regulation as part of the rule development process, and
incorporate specific GHG reduction measures into rules where
feasible. Truck GHG reduction measures (e.g., for private truck
fleets and port trucks), however, warrant special attention and
specifically, inclusion as an early action measure.  Vehicle
technologies to reduce GHG emissions and increase efficiency have
already been developed under EPA’s SmartWay Transport and
include:
single wide tires, trailer aerodynamics, automated tire inflation
and low-viscosity lubricants.  These requirements are
commercially
available and would not delay the diesel rulemaking schedule.

 

 

Add a Cement Efficiency Early Action Measure Under ARB to Group 1

We urge CARB to adopt energy efficiency requirements for cement
manufacturing facilities as an early action measure. While we
support the BT&H blended cement measure listed in the CAT early
action measure list, this measure addresses specifications for
the
composition of cement, whereas we are urging CARB to look at GHG
emission requirements for cement manufacturing facilities,
particularly in light of the fact that ARB has additional
authority to control sources of mercury emissions under its toxic
air contaminant program.. 

 

Add a Measure for Anti-Idling Enforcement

In addition, we ask you to add to Group 2, implementation of an
expanded diesel anti- idling enforcement program with at least
double the number of dedicated field enforcement staff to ensure
that appropriate resources are available to provide consistent
and
widespread enforcement of current anti-idling regulations for on-
and off-road vehicles.

 

Provide Firm Deadlines and Commitments for Measures Contained in
Tables 2 & 3

While we are encouraged to see a much broader scope of potential
emission reduction measures highlighted on your Tables 2 & 3, we
would like to see firm commitments and more specific deadlines
for
these measures.  Specifically, we believe the port rules are of
particular importance.  Adoption dates for these rules, including
shoreside power among others, must not slip on the expectation of
regional efforts to clean up port pollution.

 

We have made an effort to focus on our comments on our highest
priorities as you move toward finalizing your list of proposed
early action measures.  Given the breadth of organizations
involved in this effort, each organization listed below may not
necessarily endorse or have expertise related to every
recommendation contained in this letter.  However, all of the
organizations are united in support of full and strong
implementation of AB 32 and will continue to provide constructive
input to ARB to help ensure enactment of a comprehensive program
that meets all of the goals of the statute.  We thank you for
your
consideration.

 

Sincerely,

 
David Coale
 

 

Bonnie Holmes-Gen, American Lung Association of California

Danielle Fugere, Bluewater Network/Friends of the Earth

Susan Smartt, California League of Conservation Voters

Scott Smithline, Californians Against Waste        

Rachel McMahon, Center for Energy Efficiency and Renewable
Technologies

Tim Carmichael, Coalition for Clean Air

Joel Bush, Communities for Clean Ports

Tam Hunt, Community Environmental Council

Jason Barbose, Environment California

Devra Wang, Natural Resources Defense Council          

Michelle Passero, Pacific Forest Trust

Matt Vander Sluis, Planning and Conservation League

Bill Magavern, Sierra Club California

Patricia Monahan, Union of Concerned Scientists