Comment Log Display

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

E. Enforcement (p. 109)

 • Sierra Club agrees that enforcement is a critical component of
AB 32 implementation. CARB will need to significantly bulk up its
enforcement resources to meet this challenge. In addition, the
scoping plan should explain the route for enforcing emission
reduction measures taken by other agencies outside CARB to hold
those agencies accountable for assuring the realization of emission
reduction measures assigned to them.

•  We support the measures proposed for enforcement, especially
including engaging local Air Quality Districts in tracking
emissions from local facilities.

•  We would support allocating some program funding to these Air
Quality Districts to support their increased duties under AB 32.

F. State and Local Permitting Considerations (p. 110)

•  We support including state and local permitting considerations
in the AB 32 implementation strategies.

•  We would support allocating some program funding to the
entities involved to support their increased duties under AB 32.

G. Role of Local Air Districts (p. 111)

•  Sierra Club would support allocating some program funding to
Air Quality Districts to support their increased duties under AB
32.

H. Program Funding (p. 112)

• We support the measures proposed for program funding, including
collection of fees.

V. A VISION FOR THE FUTURE (p. 113)

•  We support collaboration with key partners, as long as it
doesn’t dilute the effectiveness and speed of implementation.
California needs to stand up for a high standard of GHG reductions,
not sink to the “lowest common denominator.”

•  We applaud the planned expansion of research by California’s
universities to develop innovative solutions to all aspects of the
plan, but we cannot wait for the “perfect technologies.”