Comment Log Display

These comments are in response to the California Air Resources
Board (CARB) Notice of Public Hearing to Consider Adoption of
Proposed Regulations for a California Renewable Electricity
Standard – set for hearing on September 23, 2010. 

Western Area Power Administration (Western), a federal agency,
appreciates the CARB’s acknowledgement of Western’s previous
comments; however, as previously stated, Western continues to
express concerns that the CARB’s regulations include Western as a
regulated entity.  Western refers the CARB to Western’s previous
comments and Western will not restate those comments here.

Rather than continuing to identify Western as a regulated entity,
the CARB should create a new definition in Section 97002 titled
“Cooperating Agency”.  The CARB could then define Cooperating
Agency to include Western.  Western notes there are numerous places
where the proposed regulations specifically identify Western and
the Department of Water Resources for different treatment than
other Regulated Parties.  In the proposed regulations, CARB often
treats Western and DWR in the same fashion.  As a result, rather
than identifying Western and DWR as a “Regulated Party” in the
regulations, Western encourages the CARB to create a new definition
for Western and DWR.  For instance: (1) CARB could remove the
references to Western and DWR from Section 97006 (a)-(d) and change
97006(f) to “Reporting by Cooperating Agencies --  Beginning July
1, 2013, and July 1st of each year thereafter, Cooperating Agencies
shall voluntarily submit the following information for the prior
calendar year to ARB:”;  (2) Remove the references to Western and
DWR from Section 97004(a) and change 97004(d) by deleting DWR and
Western and substituting Cooperating Agency.  Along these same
lines, Western also would recommend creating a new subsection (c)
in 97009 that states “No part of this section 97009 shall apply to
a Cooperating Agency.”

If you have any questions with regard to the above, please feel
free to contact me at (720) 962-7017 or kawamura@wapa.gov.
							
Koji Kawamura