Comment Log Display

California has a unique opportunity right now to set an example for
the nation in how we collectively attack the problem of global
warming.  CARB should be commended for developing a  Scoping Plan
that is appropriately ambitious.  But, I write to encourage CARB to
make sure that the potential of this Plan is not destroyed by a
failure to address the details.

Cap and trade can be an effective method of reducing emissions,
but CARB's current Plan still does not specify how polluters will
receive these credits.  European countries provided emission
credits for free to their industries, which contributed to the
crumbling of their nascent cap-and-trade system.  Please do not
subject us to the same mistake.  To provide the appropriate
incentives (and disincentives), all of these emission credits
should be auctioned.  Not only will this contribute to faster
adoption of clean technologies, but revenue from such an auction
can be reinvested to create green jobs and aid low-income consumers
and small businesses in reducing their energy bills.  In addition,
CARB should place greater immediate emphasis on other market
mechanisms, such as feed-in tarrifs and carbon fees.

It is disappointing to see that offsets are still playing a role
in the Plan.  Allowing offsets often encourages continued emissions
in low-income neighborhoods and in defenseless habitats.  It also
weakens the demand for clean energy technology and green jobs in
California.  Any offsets allowed should at most represent only a
small portion of a polluter's required emission reductions.  To the
extent that CARB retains offsets in the Plan, please inclue
stringent protocols ensuring that the reductions are quantifiable,
new, permanent, subject to independent third-party verification,
enforceable by CARB, and only located in California. 

CARB should be commended for including a 33% renewable electricity
standard by 2020, but standards can become simply aspirational if
they are not given the force of law.  Please couple this standard
with approprate regulatory action.  In addition, please make it
easier and more affordable for California communities to meet and
exceed this standard by promoting and enabling Community Choice
Aggregation.

Thank you for all of your work in developing this Plan and in
seeking public comment.