Comment Log Display

NOTE: The following letter from the Southern California Association
of Governments (SCAG) President Richard Dixon was also mailed to
the ARB.

August 11, 2008



Mary D. Nichols, Chairman
California Air Resources Board
1001 "I" Street
P.O. Box 2815 
Sacramento, CA 95812

Dear Ms. Nichols:

On behalf of the Southern California Association of Governments, I
am pleased to submit these preliminary comments on Climate Change
Draft Scoping Plan.  The Draft Scoping Plan begins to describe the
tremendous challenge that has been given to your board under AB 32.
 

SCAG, as you know, is a Metropolitan Planning Organization (MPO)
charged with preparing transportation, air quality, and other
plans under various State and Federal laws.  We are also a member
organization comprised of 167 member cities and six counties in
the Southern California region.  We have been a partner with your
agency in planning for clean air for nearly four decades.

We are encouraged that the Draft Scoping Plan recognizes the
potential for regional planning and collaboration to achieve air
emissions benefits.  Of note, the Draft Scoping Plan proposes two
million metric tons of CO2 equivalent reductions to be achieved by
local agencies through regional blueprint planning processes in
2020.  
We recognize, however, that while the Draft Scoping Plan and
Appendices lay out broad parameters under which regional targets
for greenhouse gas (GHG) emissions reductions might work, there
are many significant issues that would need to be fully addressed
in order for our members to move this measure forward.  Major
examples include the appropriate level of the local government GHG
reduction target (and any potential associated vehicle miles
traveled reduction target), the technical methods to establish and
verify emissions reductions, accountability measures, and
commitment to incentives and funding for local participation.  

Please note that a one-size-fit all approach may not be
appropriate, and urge you to work with SCAG to further consider
the breadth and complexity of the Southern California region, and
to coordinate with us in your outreach to the variety of
stakeholders here.






ARB staff has been accessible to SCAG staff, and I appreciate the
willingness of your staff to work with us on discussing these
issues.  Nevertheless, I strongly encourage you to have additional
focused discussions with MPOs around the State and with
representatives of local governments.

Finally, please be aware that while we are submitting preliminary
comments to respond to the August 11 deadline, we have not to date
convened a full policy review and discussion involving SCAG’s
Regional Council.  To that end, a Climate Change Workshop has been
scheduled for September 4, 2008, the next meeting date of the SCAG
Regional Council.  It is our intention to submit further comments
to you after the Workshop, but in advance of anticipated adoption
of the Scoping Plan in November.  

I am pleased that ARB will participate in the Climate Change
Workshop discussion with the Regional Council when it meets on
September 4.  The Workshop will provide an opportunity for direct
discussions with representatives of SCAG member cities and
counties.

Thank you again for the opportunity to comment on the Draft
Scoping Plan.  We look forward to working with you on this
important effort.

Should you have any questions regarding this letter, please
contact Mr. Hasan Ikhrata, Executive Director, at (213) 236-1944
for further information.

Sincerely,
 
 
RICHARD T. DIXON
President
Southern California Association of Governments