Comment Log Display

Comments to ARB on proposed scoping plan
Carlos Davidson
Associate Professor/Director Environmental Studies Program
San Francisco State University
November 19, 2008

I commend the ARB staff for depth of work and the comprehensive
nature of the plan. While it might be possible to get to the 2020
goals with more focused and deeper emissions cuts, a comprehensive
approach is a necessity to put us on a path to reach the need 2050
goals. I also commend the ARB for the public health and economic
analyses that accompany the scoping plan. As a result of these
analyses it is great to see that the scoping plan will result in
overall improvements in public health and net economic benefits.  

In addition to the aggregate economic analysis it would be good to
see analysis of distributional impacts - will low income people
bear a disproportionate burden? Will they be able to realize the
energy efficiency savings in transportation and in residential
energy. or will those savings only be reaped by higher income
brackets? If there is a disproportionate burden on lower income
Californians then I would like to suggest that ARB pursue the
scoping plan suggestion to use auction revenue to mitigate that
burden. If auction revenue was used to give additional incentives
to low income Californians to switch to fuel efficient cars,
insulate homes, install solar power or water heaters, and subsidize
public transit, it would help reduce the financial impact of rising
energy prices. And it would provide two additional benefits: it
would encourage further emissions reductions than would be possible
without these programs, and it would help ensure that “being green”
is not perceived as something only for the more well to do. To
reach our goals beyond 2020 we need a broadly accepted culture of
striving for reduced emissions. 

The plan is way to timid in its approach to allowance auctioning.
It acknowledges the many good reasons to have 100% auctioning but
then simply calls it a worthwhile goal, with no commitments or no
timelines. The Greenhouse Gas Initiative in the northeast started
out with 100% auctioning. California should do the same. At a
minimum the plan should at least start with 50% and have a firm
commitment to reach 100% in a few years.

Allowing 49% offsets in meeting emissions allowances is
counterproductive. The failure of the Clean Development Mechanism
offsets has shown that establishing additionality is difficult.
There are huge financial incentives for deception. This means that
offsets will require costly design, enforcement and monitoring
effort – effort that could be better placed into direct real
emissions reductions. I would urge the ARB to limit the use of
offsets to 10% of emissions allowances.

Thank you for considering my comments.