Comment Log Display

I recently attended the Bay Area Council Energy Committee meeting
as UC Davis's representative where Bob Fletcher presented the
proposed low carbon fuel standard in the Scoping Plan and Theresa
Cho (CPUC) presented their Building Energy Efficiency Plan.  These
and other advances are very exciting -- as usual, the state is
leading the country.

In reading the scoping plan, my attention was drawn to section D
on page 107, Tracking and Measuring Progress.  A key portion of
the Plan is understanding if we really are improving by performing
atmospheric measurements and so the Plan reads "Continuous
atmospheric monitoring of greenhouse gases may also be useful for
determining the effectiveness of emissions reduction strategies
and for future inventory development."

This phrase "... may also be useful ..." weakens the statement
unnecessarily.  As we know from long experience developing
emissions inventories for compounds such as NOx and VOCs related
to smog production, these inventories are highly uncertain.  We
know this from atmospheric measurements and modeling.  If we do
not measure greenhouse gas concentrations in the atmosphere, we
will not have any checks on the greenhouse gas emissions
inventories leaving the uncertainties unexplored.

By measuring greenhouse gases and a range of co-pollutants, we
cannot only verify the GHG emissions inventory, but also associate
shortcomings in the inventory with emissions sources because
processes that emit greenhouse gases also emit other compounds and
particles that identify the sources.

Obviously, this is way too much detail for the scoping plan.  The
point of this comment is to encourage that this portion of the
plan be strengthened.  I suggest that the wording be changed to
"Continuous atmospheric monitoring of greenhouse gases is
essential for determining the effectiveness of emissions reduction
strategies and for future inventory development."