Comment Log Display

SMUD  -  Oral Version  -  Beebe  -  [3 minutes]
Items for CARB public comments to be presented Nov 20th with
written follow-up 

We appreciate the hard work that the ARB staff has done in putting
together a comprehensive approach to meeting the AB32 targets. SMUD
supports the electric sector programmatic measures; the 33% RPS,
the energy efficiency targets, the California Solar Initiative, and
the need for allowance trading. 

[Don’t start Cap & Trade without Transportation Sector]  With
respect to cap and trade, one of the most important considerations
that the ARB has maintained throughout the development of the
Scoping Plan has been one of fairness. We applaud this. However,
the scoping plan shows the electric sector and industrial sectors
subject to a cap in 2012, but the transportation and natural gas
sectors not until 2015. Not requiring allowances to be held by
transportation and natural gas amounts to preferential treatment
and places considerably more burden for paying for AB32 upon the
electricity and industrial sectors.  This is a fairness issue that
cannot be overlooked.

[Specific inclusion of some early offset programs needed now.] 
The PSP makes the case that inclusion of emissions offsets will
help mitigate allowance prices under cap and trade. Today, the
carbon offset industry in California is truly just getting started.
Available protocols that might enable compliance are limited.
Development of projects under those limited project types are very
preliminary, and projects take years to provide first reductions.
SMUD has had some experience with this through our voluntary
customer carbon offset program for which we are developing two
dairy digester projects and are soliciting additional offsets
through competitive bids.  But to truly help, ARB could accelerate
its carbon offset protocol process and fast-track adoption of
regulations under H & S Code § 38571 to verify and enforce
reductions so that verified offsets can be banked early and used
for compliance in 2012.
   
 [Linear reducing cap not practical]  As required, the Scoping
Plan identifies sufficient Greenhouse Gas emission reductions to
enable California to meet its emissions goal by the year 2020. 
However Figure 1 of Appendix C shows, significant mandatory
reductions are expected to occur even in the earliest years of the
program and continue evenly throughout the period.  We are unaware
of specific investigations that show how the Scoping Plan programs
will produce this linear reduction of emissions with time.  It’s
clear that such investigations will be needed before setting yearly
emission caps.  Simply assuming that a linear reduction in
emissions is achievable is insufficient, and could well increase
costs unnecessarily. 

Thank you for your consideration of our comments, these and some
additional suggestions will be submitted in written form.   Thank
you.