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Comment 7 for Proposed Short-Lived Climate Pollutant Strategy (slcp2016) - Non-Reg.

First NameDylan
Last NameRoss
Email Addressdylanbross@gmail.com
Affiliation
SubjectAn Educated Public Comment on SLCP Reduction Strategy Proposal
Comment
Dear Sir or Madam, 

Thank you California for taking the time and money to study such an
important issue in our modern time. I read the proposed strategy
and I see a great vision for positive change in our future. Yes,
clean air and minimizing climate impact is quite a challenge in the
world today. Nevertheless, with the multi-faceted approach set
forth in your reduction strategy I can only hope we gain the
financial and political support to push this through. 

I have two comments. First, I understand the proposal defers to the
many mature and ongoing clean energy programs with respect to
emissions from industrial power plant sources. However, I believe
the proposal should consider then the impact of losing California's
single largest emission-free power source, Diablo Canyon Power
Plant. There is no power source in California that even comes close
to the zero-emission, high availability, low cost, and role-model
safety record, than Diablo Canyon. The proposal goes as far to say
"many of these facilities [biomass power plants] face expiring
power contracts and are shutting down or in danger of doing so. In
the near term, a priority is to keep existing facilities operating
that receive woody biomass from high hazard areas, as called for in
the Governor’s Proclamation." Yet, the value gained by preserving
these old, poorly maintained, biomass power plants is a drop in the
ocean compared to the value gained from continuing to operate 2300
megawatts of clean energy. Why was Diablo Canyon not addressed in
this proposal?

Second, did you know the State Lands Commission (SLC) has been
reluctant to extend Diablo Canyon's ocean intake permits past 2018?
Has California realized the dramatic increase in carbon emissions
that will fall out from the premature retirement of Diablo Canyon?
If the ARB has any ties with the SLC, I urge you to communicate to
them the counter-productive dig to your proposal if Diablo's
clean-air influence were lost. The SLCP reduction strategy proposal
also suggests reducing methane by way of "transitioning aways from
its use of natural gas" or by "minimizing natural gas leaks". Did
you know that when San Onofre Nuclear Generating Station (SONGS)
shut-down the State & Utility together have decided to replace the
power with over 1000 MW of natural gas burning plants? The same, or
worse, will happen when we lose Diablo Canyon. More natural gas
burning power plants requires more natural gas transmission
pipelines and compressor stations, resulting in a higher risk of
leaks and more carbon-emissions. Again, every day that Diablo
Canyon is running is another day our state maintains the national
lead on clean air practices and mitigates unnecessary state program
expenses on less impacting legislations.

I respectfully submit this comment with the hope that it will be
seriously considered. I have worked as an engineer in the power
industry for 10 years; from gas-fired, solar thermal, solar PV, to
nuclear. I've worked on projects from concept to design and
start-up to operation. Optimization in performance, cost, safety,
reliability, and feasibility are required of my daily work. This
should lend enough credibility for you to seriously consider my
comment. 

Respectfully,
Dylan Ross
Licensed Mechanical Engineer

Attachment
Original File Name
Date and Time Comment Was Submitted 2016-04-27 21:32:58

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