Comment Log Display

November 18, 2008

Mary Nichols, Chair
California Air Resources Board
1001 ‘I’ Street
Sacramento, CA 95814

Re: Climate Change Proposed Scoping Plan

Dear Ms. Nichols:

I understand that the Air Resources Board (ARB) is about to adopt
a Scoping Plan for reducing carbon emissions, including a
cap-and-trade program. Mendocino Wine Company urges ARB to include
specific language that supports the ability of voluntary purchasers
of renewable energy to reduce greenhouse gas (GHG) emissions below
the level of the cap. Doing so will allow voluntary markets to help
California exceed its goals for renewable energy development and
GHG reductions. 

We are one of many organizations voluntarily purchasing renewable
energy certificates (RECs) and generating on-site solar power as
part of our commitment to reducing the greenhouse impact of our
operations on the global environment.  We refer to these purchases
generically as renewable energy.

As long as California has been without a fixed cap on GHG
emissions, we feel confident that our purchases have displaced
fossil generation and resulted in emission reductions.  In this
situation, we can make public statements about how we are reducing
emissions, and these claims can be easily substantiated. 

When a fixed cap on emissions is established under AB 32, starting
in 2012, voluntary purchases of renewable energy will still
displace fossil generation, but the number of emission
allowances—and hence the level of emissions produced—will be
unaffected, and our emission reduction claims will become
problematic.  It is our understanding that unless allowances are
retired commensurate with our renewable energy purchases, starting
in 2012,   renewable energy purchases will no longer reduce GHG
emissions. This is a result we hope the State of California will
agree is unacceptable.  

We further understand that the rules to implement the
cap-and-trade program will be written in 2009 and 2010, but the
Scoping Plan does not include explicit direction to include the
emission reduction value of voluntary renewable power purchases. 
Since the Scoping Plan is widely recognized as the “roadmap” for
future rulemaking, we are concerned the important market-based
emission reductions taken by our company and other voluntary
stakeholders will be left off the table.   

We ask, therefore, that the Scoping Plan clearly recognize
voluntary purchases of renewable energy, renewable energy
certificates and on-site renewable generation for the GHG emissions
reduction benefits that they provide. The Scoping Plan should
explicitly acknowledge the emission reductions created by voluntary
renewable purchases by companies such as ours and state that the
role of voluntary renewable purchases in achieving California’s
goal will be developed and described in the cap-and-trade formal
rulemaking.

Thank you for considering our comments.

Sincerely,


Kelly Lentz
Marketing & Sales Coordinator
Mendocino Wine Co.