Loading...
HomeMy WebLinkAbout11-11-20 Public Comment - M. Lilly - Draft Climate Change commentFrom:Mike J Lilly To:Agenda Subject:Draft Climate Change comment Date:Wednesday, November 11, 2020 4:03:29 PM Attachments:Climate change submission.docx Attached are comments I would ask the Commission consider when reviewing the Draft 2020 Climate Plan. Michael J. Lilly mikelilly@berglawfirm.com Berg Lilly, PC 1 West Main Street Bozeman, Montana 59715 Telephone: (406) 587-3181 Fax: (406) 587-3240 This electronic mail transmission may constitute an attorney/client communication that is privileged by law. It is not intended for transmission to, or receipt by, any unauthorized persons. If you receive this transmission in error, please delete it from your system without copying it and notify the sender immediately. Internal Revenue Service regulations provide that a taxpayer may rely only on formal written advice meeting specific requirements to avoid federal tax penalties. Any tax advice in the text of this message, or in any attachment, does not meet those requirements and, accordingly, is not intended or written to be used, and cannot be used, by any recipient to avoid any penalties that may be imposed upon such recipient by the Internal Revenue Service. Bozeman’s Draft 2020 Climate Plan sets ambitious goals – a 26% reduction of emissions from a 2008 baseline by 2025, 100% net clean energy by 2030 and complete carbon neutrality by 2050. It identifies a number of solutions to achieve those goals. Solution B calls for Achievement of Net Zero Construction by 2025 and Solution C seeks complete electrification of all buildings by 2050. The Plan then identifies a number of steps to be taken to implement those solutions. The Plan overlooks the role Bozeman’s approval of new subdivisions can play in achieving its climate goals. The Montana Subdivision and Platting Act requires Bozeman to “avoid subdivisions that would involve unnecessary environmental degradation.” The Act requires Bozeman to review the environmental impacts of a proposed subdivision. The Act allows Bozeman to impose conditions upon the approval of a subdivision to mitigate “those significant adverse impacts identified” in the review process. The Draft Climate Plan reveals that Bozeman’s community emissions have increased since 2008. That increase is largely related to a population growth. Fifty-four per cent of those emissions were attributed to new buildings. For this reason, new subdivisions have the potential for significant adverse impacts upon climate change. Bozeman should require the Environmental Assessments required for all proposed subdivisions to analyze their impact upon climate change. Climate change is “environmental degradation”. Bozeman should then consider imposing conditions upon the approval of those new subdivisions to mitigate their potential impact on climate change. The Bozeman Climate Plan calls for a carbon neutral environment by 2050. That goal requires a transition from natural gas to complete electrification. The first step toward reaching that goal can be taken now by conditioning the approval of all construction in a proposed subdivision upon the requirement that its power source be electricity. It makes no sense to allow buildings in a proposed subdivision to be powered by natural gas when Bozeman plans to pursue complete electrification in all buildings by 2050. By conditioning the approval of a subdivision upon the requirement that its power source is electricity, the cost of retrofitting a building utilizing natural gas to electricity in the future can be avoided. More importantly, Bozeman can accelerate its efforts to reduce greenhouse gas emissions by addressing the need to eliminate natural gas use now rather than later. Bozeman has the power to take these steps now. By taking these steps now, Bozeman can minimize the impacts new development has on its climate goals. Consequently, the 2020 Climate Plan should include the use of the Montana Subdivision and Platting Act as a tool to transition from natural gas to electricity, accelerating its goal of complete electrification of buildings.