First Name | Edward |
---|---|
Last Name | Mainland |
Email Address | emainland@comcast.net |
Affiliation | Sierra Club California |
Subject | Sierra Club Comment on Enforcement, Permitting, Funding, Future Vision |
Comment | COMMENTS ON AB 32 PROPOSED SCOPING PLAN, SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008 E. Enforcement (p. 109) • Sierra Club agrees that enforcement is a critical component of AB 32 implementation. CARB will need to significantly bulk up its enforcement resources to meet this challenge. In addition, the scoping plan should explain the route for enforcing emission reduction measures taken by other agencies outside CARB to hold those agencies accountable for assuring the realization of emission reduction measures assigned to them. • We support the measures proposed for enforcement, especially including engaging local Air Quality Districts in tracking emissions from local facilities. • We would support allocating some program funding to these Air Quality Districts to support their increased duties under AB 32. F. State and Local Permitting Considerations (p. 110) • We support including state and local permitting considerations in the AB 32 implementation strategies. • We would support allocating some program funding to the entities involved to support their increased duties under AB 32. G. Role of Local Air Districts (p. 111) • Sierra Club would support allocating some program funding to Air Quality Districts to support their increased duties under AB 32. H. Program Funding (p. 112) • We support the measures proposed for program funding, including collection of fees. V. A VISION FOR THE FUTURE (p. 113) • We support collaboration with key partners, as long as it doesn’t dilute the effectiveness and speed of implementation. California needs to stand up for a high standard of GHG reductions, not sink to the “lowest common denominator.” • We applaud the planned expansion of research by California’s universities to develop innovative solutions to all aspects of the plan, but we cannot wait for the “perfect technologies.” |
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Date and Time Comment Was Submitted | 2008-11-19 19:29:26 |
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