RCRC has, once again, provided extensive comments on a draft of CalRecycle’s Short-Lived Climate Pollutant Organics regulations, which the agency has been developing pursuant to 2016’s Senate Bill 1383 (Lara). The most recent draft was made available for 30-day comment in response to the Office of Administrative Law’s rejection of the previous draft and direction that the agency re-draft several portions of the regulations for the sake of clarity.
The most recent draft’s amendments were largely cosmetic, but it did make some dramatic changes to enforcement and penalty language that could impact local jurisdictions trying to comply with the requirements in good faith. RCRC pointed out those changes in a letter filed with the agency on May 19, 2020 and stressed the difficulties that rural jurisdictions would already face in complying with the regulations without the undue burden of the more stringent enforcement.
RCRC continues to not only pursue alternate compliance pathways for small jurisdictions, but will continue to request a delay in SB 1383 implementation due to the COVID-19 pandemic.
Read RCRC’s comments here.