Comment Log Display

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

OVERALL COMMENTS:

• We are pleased that the Proposed Plan seeks to meet the law’s
requirement of rolling back our greenhouse gas emissions to 1990
levels by 2020.
 
• Scientists now suggest, however, that goal of 1990 levels by
2020 may be inadequate. The Plan now wisely incorporates
intentional redundancies and a “margin of safety” that could
anticipate the possibility that urgent action is more pressing than
current assumptions would indicate.  The GHG concentration in the
atmosphere may be at the tipping point, as evidence of the newly
recognized rapid release of arctic permafrost and seabed methane
gives us even less time for GHG reductions before runaway warming
takes over.

• We welcome this Plan’s statement that California cannot afford
delay in reducing pollution that causes global warming. The
potential costs of inaction or delayed action are immeasurably
greater than the cost of implementation now.

• CARB's plan, which relies predominately on direct regulations
for the electricity and transportation sectors to reach the state's
2020 emission reduction goal, sets a standard for other states and
the federal government in most areas.  However, there are
substantive flaws in the plan’s approach to “cap-and-trade” and
“offsets.”  

• Sierra Club strongly supports the new plan's promises to cut
more emissions than previous drafts did. We also support the plan’s
proposal to include: auctioning of emission allowances to
polluters; more limitations on offsets; recognition of much higher
potential for recycling and zero waste; more momentum for
significant changes in current land use and transportation
planning; and more emphasis on green job creation in the fields of
clean power and energy efficiency. The Plan now makes a stronger
case for the economic and health benefits of clean energy.

• The Plan correctly points out that many powerful parallel
policies must be pursued in order to remove all the state's market
barriers and regulatory impediments to GHG reduction.  State
climate programs need the full force of CARB’s backing to such
parallel measures as Feed-In Tariffs, Carbon Fees and Community
Choice Electricity 

• We support the inclusion of co-benefits from GHG reductions such
as public health improvements and better energy efficiency.