Comment Log Display

On behalf of the Department of Defense (DoD) Regional Environmental
Coordinator for Region IX, I submit the two attached correspondence
for the administrative record in support of Second Notice of Public
Availability of Modified Text and Additional Documents and
Information (2nd 15-Day Change Notice) on the California Cap on
Greenhouse Gas Emissions and Market-Based Compliance Mechanisms
Regulation, including Compliance Offset Protocols (cap-and-trade
program).  The 16 September 2011  letter from the Assistant
Secretary of the Navy for Energy, Installations and the
Environment, Ms Pfannenstiel, to ARB's Chairwoman, Ms. Mary
Nichols, as well as the June 28, 2011 supplemental legal analysis
supporting DoD's request for a permanent exemption. 

While we appreciate ARB's recognition of the issues surrounding
Department of Defense participation in the cap-and-trade program,
and proposed section 95852.2(c) Subchapter 10, Article 5, Title 17
of the California Code of Regulations that grants a temporary
relief for emissions from NAAICS code 92811 until December 31,
2013, this temporary relief is an incomplete solution.  We ask,
therefore, that the exemption be made permanent in recognition that
DoD will address federal mandates for the reduction of greenhouse
gases (GHG).