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At the recent Oct 12, workshop a question was raised about the
geographic sourcing of offsets given the statute at Sec.
38562(c)(2)(E)(i)(I)and(II)state: "no more than one-half may be
sourced from projects that do not do not provide direct
environmental benefit in the state".  There was a suggestion that
this term was interchangeable with "in state" verses "out of state"
sources of offsets.  AB 398 does not use the term "in state".
Rather, it defines "direct environmental benefits in the state" as
follows: "...are the reduction or avoidance of emissions of any air
pollutant in the state or the reduction or avoidance of any
pollutant that could have an adverse impact on waters of the
state."  This definition allows offset projects neighboring
California to be considered on a case-by-case basis rather than an
outright exclusion of all projects that are not located in-state. 
Rather than reinterpret the intent of the Legislature, the exact
language from the statute should be used in regulations.  Thank for
the opportunity to provide comments.  
Gary C. Rynearson,
Manager, Forest Policy and Communications
Green Diamond Resource Company 

Original File Name:

Date and Time Comment Was Submitted: 2017-10-24 12:23:14