Comment Log Display

Dear Air Resources Board,

	Thank you for your innovative and bold Scoping Plan that
addresses a range of solutions for real-world climate change
action. There were some points of concern and suggestions that I
wanted to share, in hopes to contribute to the community efforts of
Californians in reducing carbon emissions, for it will take
everyone on board for the implementation and success of AB 32.

1.	The Scoping Plan says it will reduce carbon intensity of
California’s transportation fuels by at least 10% by 2020. I find
this unusually low considering the United States already had a goal
as of 2006 to reduce carbon intensity 18% by 2012.  As stated in
the Fact Sheet: Earth Day 2007 (a white house document):
http://www.whitehouse.gov/news/releases/2007/04/20070420-9.html

2.	I did not understand the reasons for making a “transition” to
auctioning of cap-and-trade permits. Let’s not forget what Europe
learned after they mistakenly gave all their permits away,
essentially billions in free money to corporations to spend as they
wished. These caps are more valuable than we know, especially down
the line once the caps acquire more pressure in time and rise in
value. The state can use the money from the auctions to support
greater infrastructure like increased power lines from renewable
sources to cities and towns or as incentives to consumers in the
mentioned feebate programs. 

3.	The 49% allowance of offsets seems high, considering
out-of-state offsets are permitted. Since California is leading the
way (amongst a few other states) with implementing cap-and-trade
and energy and transportation efficiencies, I am concerned that
states that join this carbon reducing bandwagon late in the game
might have offset properties or natural resources within their own
state already used by California businesses. A 49% reliance on
offsets might work for the short term until financial means and
technological advances help ease carbon reductions, but ultimately
they could give excuses to businesses not to comply with, adopt, or
fund research into carbon reducing technologies. Consumers, who
contribute the majority of carbon emissions through automobile use,
are reliant upon businesses for more fuel-efficient cars, since not
everyone can bike or walk or take public transit to where they need
to go. If businesses get too many breaks, what incentives will they
have to work harder and faster towards better technologies? If all
businesses are doing it, others will need to be competitive to
survive, so let’s make sure the law is clear with what is expected
from them in a way that does not permit leakage. In a sense,
offsets are leakages if they put the burden off on other states,
forcing them to preserve forestland, etc. that could be better
preserved for their own means. I would at least strongly recommend
to set target dates to gradually reduce the percentages of offsets,
with offsets in other states counting half as much as offsets
within our own state of California, for instance.

4.	There also needs to be greater accountability with utilities in
reporting their % of renewables. I work with greenhouse gas
inventories for a university in California. In collaboration with
other universities, our local electric provider PG&E says they use
20% renewables. I found out at a conference on sustainability that
that is an incorrect number (a PG&E representative was confronted
publically and admitted the truth); it is actually only 11%. Yet
every university is reporting 20% from them to the California
Climate Change Registry. That is a big discrepancy. There needs to
be a law that fines them for presenting inaccurate information,
since ultimately the atmosphere cannot be lied to. If they can do
it (and are doing it) what prevents other businesses from doing
it?

5.	There were no specifics in regards to composting programs for
commercial and residential, merely a mention of initiatives to
encourage increased collections. Incentives were mentioned, but
only in terms of exploration. Nothing about mandates or tonnage
targets were outlined.

6.	The mention of water resources and plans to conserve, recycle,
and promote system efficiencies sounds positive, but there is no
mention of how the water distributions will change as a result of
population growth. Arizona has dealt with this high-pressure
situation by making a law that prohibits water use for landscaping
and some agriculture. They converted their recreational areas back
to a desert landscape that is self-sustaining. Southern California
faces this same dilemma since they pull much of their water from
much wetter exotic lands further North and out-of-state. This
section needs serious work if we are to decrease the massive uphill
pumping of water from Northern California to Southern. A region
should not be allowed to live beyond their means and development
should slow drastically for this reason.

	Thank you for allowing commentary and feedback on this plan to
reduce carbon emissions! California has a huge global
responsibility since we are the 15th largest contributor of carbon
emissions worldwide, and I’m proud to be a citizen of a state that
is taking climate change seriously.

Sincerely,

Winona Azure
GHG Inventory Coordinator
University of California, San Francisco
415-306-3899
winona.azure@ucsf.edu