Comment Log Display

November 18, 2008

Mary Nichols
Chair, California Air Resources Board
1001 I Street 
P.O. Box 2815
Sacramento, CA  95814

RE:  Tuolumne County Chamber of Commerce Comments on Air Resources
Board Proposed  Scoping Plan

Dear Chair Nichols:

On behalf of the Tuolumne County Chamber of Commerce, thank you
for the opportunity to comment on the California Air Resources
Board’s (ARB) Proposed Scoping Plan (Scoping Plan).  

To begin with let it be clear that the Tuolumne County Chamber of
Commerce is not convinced that AB 32 is based on solid science.
There are a large number of well-known scientists that say
otherwise. Be that as it may, while the Tuolumne County Chamber of
Commerce is generally supportive of a number of programs and
policies outlined in the Scoping Plan, it is crucial for state
policymakers take account for the means that will be needed to
achieve the goals. AB 32 requires that reductions in GHG emissions
must achieve the maximum technologically feasible and cost
effective reductions and for the ARB to “consider the
cost-effectiveness of these regulations.” (HSC §38560)  In
addition, we believe that the Scoping Plan appropriately allow the
SB 375 process to develop regional transportation-related GHG
targets.  Implementations of the regional planning processes in SB
375 are new and largely untested and could cost California
companies untold millions.  The 5 MMT figure, while a place holder,
nevertheless sets an appropriate benchmark that helps assure that
the state can achieve its overall 2020 goal.”  

As both the state and local governments are faced with critical
budget shortages, additional costs to heavily invest in GHG
emission technologies in the next 2 to 3 years will become more
burdensome for businesses. The State of California has already made
itself less competitive in the market place with unnecessary rules
and restrictions. There is now an attempt to implement AB 32 with
more regulations that will continue our decreasing competitiveness.
Reality is that business and developers will only build projects
that will be purchased by willing customers and that are
profitable.   In order to effect the desired change, incentives
must be provided to the business and development communities and
local agencies in order to encourage more development in areas
where the reductions in GHG emissions will be the greatest.  The
Tuolumne County Chamber of Commerce strongly encourages the ARB to
consider these limitations as it moves forward with the Scoping
Plan.






Thank you again for the opportunity to comment.  The Tuolumne
County Chamber of Commerce looks forward to increased business in
California through reasonable implementation of a balanced
cost-effective plan to reduce greenhouse gas emissions.

Sincerely,

Jim Costello
Chairman of the Board