First Name | Dan |
---|---|
Last Name | Kalb |
Email Address | dank1@well.com |
Affiliation | UCS |
Subject | Board Members: Please Strengthen the Cap-and-Trade Rule! |
Comment | Our state's leadership in developing and implementing a cap on the pollution that causes global warming will likely have ripple effects throughout the nation and the world. Because the CA cap-and-trade program may become a model for other states and the feds, it is important that the program is designed to cost-effectively maximize emission reductions in the higher-emitting sectors. I appreciate the ARB for the public process that has led to the proposed regulation and the opportunity to provide these constructive comments. The Rule should be modified to incorporate the following: ** Clearly commit to maximize the use of auctioning as the most economically logical method of allocating emission allowances. ** Create dynamic product output-based benchmarks that reflect best practices in each given sector. ** Better identify and define CARB’s role in 'offset' decisions. ** Ensure that 'offsets' cannot be sold more than once through different registries. ** Lower the offset limit because it is way too risky to allow huge volumes of 'offsets' early in the program. ** As enforcement progresses, increase transparency. ** Require allowance value allocated to utilities to benefit ratepayers, meet the objectives of AB 32, and facilitate emission reductions above and beyond business as usual. |
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Date and Time Comment Was Submitted | 2010-12-10 15:02:20 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.