Comment Log Display

December 3, 2008

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

RE:  City of Atascadero Comments on Air Resources Board Proposed 
Scoping Plan

Dear Chair Nichols:

Thank you for the opportunity to comment on the California Air
Resources Board’s (ARB) Proposed Scoping Plan (Scoping Plan).  I
attended the November 20th hearing in Sacramento.  Unfortunately,
due to commitments at home I was unable to stay late enough to get
an opportunity to testify.

We are proud of the work we have already done on reducing our
City’s greenhouse gas emissions (GHG emissions).  I am proud that
when I was Atascadero’s mayor, I led our City to sign in support of
the US Mayors Climate Protection Agreement, and I served as
Chairperson of San Luis Obispo County’s Air Pollution Control
District Board.  Also, as former Chairperson of San Luis Obispo
County’s Economic Vitality Corporation Board, it is very important
to me to achieve a balance between protecting our environment and
our local economy.  Our City has worked to: preserve a greenbelt
around Atascadero, encourage mixed use infill development,
encourage compact development with a pedestrian scale and trails,
replace all existing lighting fixtures with energy efficient
lighting, install a new energy efficient “Green Roof” on City Hall
and much more.

I am especially concerned that the State actions you are
considering could stifle the entrepreneurial spirit which exists in
communities such as ours.  California is replete with examples
where top-down regulation has not produced results, but has
increased costs.  We are on the verge, if not in the middle of, one
of the largest financial crises faced by our State.  Please
carefully consider the economic impacts on local jurisdictions as
you adopt rules to implement AB 32.  Your actions will be critical
to our State’s success.

While the City of Atascadero is generally supportive of a number
of programs and policies outlined in the Scoping Plan, it is
crucial for State policymakers to take into account the means that
will be needed to achieve the goals. AB 32 requires that reductions
in GHG emissions must achieve the maximum technologically feasible,
make cost effective reductions and that the ARB  “consider the
cost-effectiveness of these regulations.” (HSC §38560)  In
addition, we believe that the Scoping Plan appropriately allows the
SB 375 process to develop regional transportation-related GHG
targets.  Implementation of the regional planning processes in SB
375 is new and largely untested.  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 two to three years will become
more burdensome for local governments.  While local governments can
influence development design to a certain extent, the reality is
that developers only will 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 development
community and local agencies in order to encourage more development
in areas where the reductions in GHG emissions will be the
greatest.  The City of Atascadero strongly encourages the ARB to
consider these limitations as it moves forward with the Scoping
Plan

Thank you again for the opportunity to comment.    

Sincerely,



Tom O’Malley
Council Member
City of Atascadero

xc:  League of California Cities, 1400 K Street, Sacramento, CA 
95864