| Comment | As the President of Environmental & Regulatory Specialists, Inc.
(EARSI), located in Newport Beach, California, I suggest adding a
measure requiring all new projects subject to the California
Environmental Quality Act (CEQA) to conform with the provisions of
AB32. The Calif. Attorney General and others have taken the
position that this is a requirement. See
(http://www.yubanet.com/artman/publish/article_54739.shtml)
By including this requirement, new development must implement all
feasible mitigation measures to demonstrate compliance with AB32
or the lead agency for the project must adopt finding of
overriding considerations pursuant to CEQA.
Without this early action item, State guidance will not be
forthcoming until 20011/2 at the earliest, based on ARB's
published implementation timeline.
EARSI offers CEQA Greenhouse Gas Analysis and Reduction Services.
This is mentioned to demonstrate the feasibility of this request.
Arguably, this recommendation could be the largest single
greenhouse gas reduction Early Action Measure being considered.
Feel free to contact me with questions.
Dave
www.earsi.com
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