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Dear ARB: I'm concerned that your plan is missing an important
opportunity to harness the power of consumers and markets by
relying so heavily on bureaucratic decisionmaking.  I believe a
much simpler and efficient way to achieve the carbon reductions and
enery efficiencies that we all want is by immediately setting a
carbon tax (on the hundreds of suppliers introducing carbon fuels
into our economy, rather than on the thousands of carbon-pollution
emitters).  This tax will cause the prices of carbon based fuels to
increase with the harshest effects on low- and middle-income
households.  Therefore, coupled to the tax must be a provision to
immediately, equally, and directly return the revenues collected
from the tax to those households, with several immediate and
beneficial effects: 1) mitigating the regressive effect of higher
fuel prices, 2) putting dollars in the hands of those families most
likely to spend them immediately and thereby boost our stagnant
economy, and 3)providing funds for more strongly incentivized
consumer spending for efficient vehicles and other energy
technologies. 

I fear that the approach laid out in your plan will take years to
design and implement because it has so many decisions that need to
be made with input from so many stakeholders.  Instead, let's make
it quick and simple: 1) send a strong price signal to consumers to
move away from carbon-based fuels, and 2) give those consumers the
ability to select in the marketplace new, efficient, and noncarbon
based technologies (e.g. autos, mass transit, foods, packaging
materials, etc. etc.).

Thanks for your efforts.  Please see www.capanddividend.org for
info about how such measures can work.