Comment Log Display

COMMENTS ON AB 32 PROPOSED SCOPING PLAN,
SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008

II. RECOMMENDED ACTIONS

A. ROLE OF THE STATE: SETTING AN EXAMPLE (p. 24)

• Sierra Club applauds the explicit commitment of the state
government to lead by example, with a target of a minimum of 30
percent reduction by 2020.  We encourage immediate implementation
of all the actions listed, plus more to be identified. 

B. ROLE OF LOCAL GOVERNMENT: ESSENTIAL PARTNERS (p. 26)

•  Sierra Club is pleased that SB 375 requires CARB to work
closely with local governments to establish strong regional targets
for greenhouse gas reduction through the SB 375 process.

•  We believe CARB’s goal for local governments of a 15% GHG
reduction from current levels by 2020 is feasible.

•  CARB should set a higher goal of at least 11 million metric
tons in greenhouse gas reductions to be achieved from reductions in
vehicle miles traveled. We believe research supports the
feasibility of a higher goal. 
 
•  CARB should provide substantial technical and financial
assistance to local governments, in addition to guidance protocols,
to help them reduce greenhouse gases from transportation and land
use, as well as other sectors, including energy and recycling. 
These governments are fiscally hard-pressed by the economy's
downturn and credit collapse. Many are facing employee layoffs. 
They do not have the talent or expertise to devise and execute such
GHG plans. They also need financial and technical assistance from
state and federal sources; compliance will be difficult without
that aid.

•  SB 375 is insufficient by itself.  Needed also are tools for
local governments to translate GHG reduction targets into local
action.

•  CARB should actively promote and facilitate Community Choice
Electricity Aggregation (AB 117, 2002), which Sierra Club believes
is the single most potent step municipalities can take to quickly
reduce their greenhouse gas emissions substantially in the next
decade.