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Comment 15 for California Cap-and-Trade Program (capandtrade10) - 15-2.

First NameZeynep
Last NameErdal
Email Addresszerdal@ch2m.com
Affiliation
SubjectCARB Cap and Trade 2nd Round of Proposed Revisions
Comment
Dear Sir/Madame;
In October 2010, CARB released the proposed regulation for the cap
and trade program.  In a later meeting with CARB staff, the staff
agreed to add language to Section 95852.2, Emissions without a
Compliance Obligation, under Fugitive and Process emissions, “CH4
and N2O from Municipal Wastewater Treatment Plants.”  The sheet
with that change (Attachment B) was introduced at the December 16,
2010 Board meeting where all the documents were approved by the
Board, but the Resolution 10-42 required that Attachment B be
subject to 15-day public review, and comments considered. 

The first 15-day package was release in July 2011.  The language
cited above was contained in this package.  To our knowledge, no
negative comments came were received addressing this specific
language.  Unfortunately, the second 15-day package released
removed the language with no explanation. 

It is our opinion that if there were no negative comments from the
first 15-day period, the above listed language should not have been
removed from the document. We respectfully request correction of
this oversight as part of the second round of review comments
processing at this time. 

If you have any questions or need further clarification of our
position, please do not hesitate to contact me at 714-435-6145.

Sincerely,
Zeynep Erdal, PhD, PE
for California Wastewater Climate Change Group (CWCCG)

Submitted on September 26th, 2011

Attachment
Original File Name
Date and Time Comment Was Submitted 2011-09-26 15:53:46

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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