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Comment 35 for AB 32 Scoping Plan (scopingpln08) - .

First NamePieter
Last NameTans
Email AddressPieter.Tans@noaa.gov
AffiliationNOAA Earth System Research Laboratory
SubjectSection IV D Tracking and Measuring Progress
Comment
Section IV D of the proposed scoping plan can be improved in
essential ways in my opinion.  In the process of severely reducing
emissions, enormous investments will be made by government, the
private sector, and individual citizens.  We need to know to what
extent each of these policies or strategies is really successful as
opposed to what is being claimed for them or desired.  It would be
foolish to rely primarily, as the current plan appears to do, on
claimed reductions.  These accounting practices are indeed
necessary, but society needs independent verification, on the scale
of counties and states, of the accounting in the place where it
counts, namely the atmosphere itself.  There is too much money at
stake, nor can we afford the climate risk of mitigation measures
being not as effective as we hope they are.  I'll mention just two
examples, out of many, pertaining to emissions inventories.  There
is overwhelming evidence from atmospheric measurements that the EPA
overestimates U.S. emissions of carbon monoxide by a factor 2-3. 
There is also good evidence that they underestimate sulfur
hexafluoride emissions (reported to the UN Framework Convention on
Climate Change) by a factor of ~two. 
What I would like to see CARB propose is a plan to combine GHG
measurements with many other chemical species, many of which are
already being measured, such as HCFCs, HFCs, CO, hydrocarbons, etc.
 The observation of correlated variations in the atmosphere helps
to apportion the variation of GHGs to specific processes, and
simultaneously it allows for better quantification of the emissions
of species contributing to air pollution.  To be fully effective,
all of these measurements need to be a part of, and embedded in, a
larger framework.  Air flows into, above, and out of California,
contributing to information about emissions in California. 

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Date and Time Comment Was Submitted 2008-11-10 09:09:10

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