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Many local governments are already implementing policies and
programs that are aimed at reducing energy consumption and
greenhouse gas emissions. ARB 2-6 (Guidance and Protocols for
Local Governments) will be considered by the ARB in the 3rd
quarter of 2008, far too late to make it relevant to the growing
number of cities that are seeking guidance and support from the
State right now. 

The Institute for Local Government (ILG)is already addressing ARB
2-6 in its Best Practices Certification Program due for release
before the end of 2007. The ARB would do well to partner with the
ILG to bring these protocols forward and avoid a duplication of
effort.

The recommendation for Cool Communities Program described in
SCAQMD - 3/ARB 2-9 is that these programs be non-regulatory and
voluntary. If these programs (Cool Roofs, Cool Pavements, and
Urban Forests) have the potential to make significant reductions
in greenhouse gas emissions, then they should be made mandatory
and be accompanied by financial or other incentives that make it
possible for cities to particpate.

Seventy five percent of all greenhouse gas emissions are produced
in our cities. Cities throughout the State are indicating their
willingness to reduce their emissions, but are hampered in that
effort by a lack of human and financial capacity to make a
meaningful contribution. The State could help by putting
additional resources into local governments that are ready to do
their part.