🚀 go-pugleaf

>
>My name is Kevin Hsieh and I'm a Biology/Public Policy Analysis major at Pomona
>College.  I'm researching the South Coast Air Quality Management District's
>(SCAQMD or just AQMD) Regional Clean Air Incentives Market program (RECLAIM). 
>I'm looking for _INFORMED_ fact and opinion regarding this new program. 
>Comments from businesses, environmentalists, politicians, and concerned
>citizens is welcome.  Just to jog your memory, RECLAIM is a new program that
>started Jan. 1 designed to reduce NOX and sulfur oxides through market
>incentives.  If I describe the program any more, I'm less likely to get
>informed opinion.  Sorry.  :-(
>
Kevin,  You will find that SCAQMD has taken a considerable amount of 
public comment on RECLAIM, all of which is on the public record.  I 
suggest that you go to Diamond Bar and read the administrative record of 
the rulemaking.

I practice environmental law in LA.  Here is what I think of RECLAIM:

1.  A noble effort.  Too many times environmental programs are merely 
tinkered with when they need to be entirely reconsidered.  I applaud the 
effort.

2.  The monitoring and recordkeeping provisions are too burdensome for 
doing business in the real world.

3.  Application of the program is unfair.  Some businesses which were 
built to comply with NSPS have little to nothing they can do to reduce 
emissions past current levels.

4.  Too driven by theory and ideology.  Who really thinks that using the 
"marketplace" as a metaphor for controlling emissions is meaningful 
except for libertarians and conservative idealogues.  

5.  It has diverted too many resources from the challenge at hand.  
SCAQMD has major challenges facing it in meeting mandated deadlines.  
RECLAIM has sucked too many resources into an experimental effort.
-- 
Sherry Katz - slkatz@netcom.com
Graham & James
Los Angeles, CA