Comment Log Display

COMMENTS ON AB 32 PROPOSED SCOPING PLAN,
SUBMITTED BY SIERRA CLUB CALIFORNIA, 
November 19, 2008

To California Air Resources Board Members and Staff:

Sierra Club California commends CARB’s forward movement on this
comprehensive, far-reaching AB 32 Proposed Scoping Plan.  It can
ultimately be a model for the nation and the world. The Plan will
help California build a stronger, cleaner economy that will create
jobs, protect us from oil price surges, and reduce pollution that
causes climate disruption. 

Sierra Club welcomes this opportunity for comment.  At this
critical decision point, and in ensuing years as AB 32
implementation measures are developed in more detail, Sierra Club
will continue to press for those high-priority measures most likely
to move us forward quickly to a low-carbon energy economy while
maintaining fairness and equity.

CARB’s Proposed Scoping Plan is moving in the right direction.  We
support the ten specific changes on pages 3-4. We recommend further
strengthening, however, before the Plan is adopted in December.
Sierra Club’s volunteers and staff have prepared a full set of
comments, presented below.

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Our top priorities for changes in the Proposed AB 32 Scoping Plan:


1) Concentrate on carbon fees to generate revenues, but if
cap-and-trade is used, CARB should commit to a rapid implementation
of 100% auctioning of allowances..  If offsets are allowed, they
must be very limited, located only within or near our state’s
border, and have no adverse impacts on environmental justice.
Program revenues should go toward GHG reduction programs, such as
clean technologies, green jobs, and aid for low-income consumers
and small businesses.

2) Increase the goals for emissions reductions from lower vehicle
traffic by enforced regional land use planning requirements.

3) Require commercial recycling and take meaningful steps toward
for zero waste and Extended Producer Responsibility (EPR).
 

Additional priorities include: 

1) Consider cap-and-auction just one tool among market mechanisms.
Other tools should be brought forward more robustly, including
feed-in tariffs and carbon fees in the Plan’s near-term action
agenda. See details in the following pages. 

2) Make sure the 33% renewables electricity standard is achieved
before 2020, either through legislation or regulatory action. 
Promote and enable Community Choice Electricity Aggregation (CCA)
and feed-in tariffs as potentially powerful GHG reduction
mechanisms. Implement the CPUC RPS Report, October 2008, which
states (p. 10): “If the state is required to generate 33% of its
energy from renewable resources by 2020, then all new procurement
of new energy resources between now and 2020 must be entirely
renewable energy, except some new fossil for peaking capacity and
to replace aging fossil plants critical to renewable integration.”

3) Give more specificity and amplitude to the goal of electrifying
transportation, especially greatly expanding ZEV numbers (plug-ins
and electric cars) beyond CARB's currently too low projected
levels.   This would reap huge GHG reductions.

4) Place a higher priority on reducing methane emissions, since
the Plan greatly underestimates the significance of methane
emissions by using the 100-year global warming potential. Over a
shorter time horizon, methane accounts for 17% to perhaps well over
30% of the state’s GHGs, rather than the 5.7% indicated in the 2004
inventory. 

5) Ensure that actions to reduce greenhouse gases also help,
whenever possible, to clean up California’s unhealthy air,
especially in already highly impacted areas.