Comment Log Display

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


E. VOLUNTARY EARLY ACTIONS AND REDUCTIONS (p. 67)

• Sierra Club is pleased CARB is studying means to reward
voluntary early actions reductions.


F. USE OF ALLOWANCES AND REVENUES (p. 69)

• We support most of the uses listed, particularly those related
to environmental justice, such as “achieving environmental
co-benefits.”  However, we are not supportive of “direct refund to
consumers,” unless such “refunds” can be tied directly to GHG
reductions.

• Criteria and toxic air pollutants create health risks, and some
communities bear a disproportionate burden from air pollution. We
support ideas that benefit these unfairly impacted communities.

• Revenues should be prioritized for projects that reduce both GHG
emissions and also provide reductions in air and other pollutants
that affect public health.

• We are pleased that CARB has provided a positive discussion of
carbon fees. We think that the range of $10 and $50/ton would be
reasonable; this fee could start low and gradually increase over
time as needed.

• A $30-per-ton fee on all greenhouse gases would provide revenue
of approximately $12 billion per year, which is less than 1/100th
of the California economy. This money could be restored immediately
to the state economy, encouraging local investment in clean
technologies and green jobs, activities with a bright prospect in a
carbon-constrained world. Revenues could also provide rebates for
low-income consumers.

• We believe that it should be possible to quantify some of the
benefits from the expenditure of the funds on projects that provide
considerable GHG emission reductions. For example, transit
operators know increased frequency of service and lower fares can
increase ridership. Recovering waste heat, either to generate
electricity or from generating electricity, has specific value to
commercial and residential utility customers.

• On carbon pricing, emissions fees should be analyzed along with
a cap-and-auction system, as the Plan proposes. We need the income
to fund CO2 reductions.

 • Polluters always should have to pay for cleaning up the damage
they cause. Therefore, if a carbon market is established, all
emission allowances should be auctioned. The Plan states (page 16),
“These allowances could be freely distributed to capped firms or
auctioned in the trading market.” We are opposed to free
distribution of allowances, since they don’t encourage
accountability and provide much less motivation to reduce GHG
emissions.

• Major emitters should pay for the cost of administering this
program.


III. EVALUATIONS (p. 73) 

Specific economic benefits of energy efficiency and clean energy
measures can be evaluated based upon the sum of:
 1) Projected and avoided costs for these energy supplies,
2) In-state jobs and manufacturing due to green economic
activity,
3) Federal tax credits benefits and in-state tax revenues,
4) Export revenues, and
5) Environmental and public health benefits.

• CARB’s analysis of public health benefits of transportation
efficiency measures focuses only on respiratory medicine and
economic benefits of reducing respiratory disease. While this
analysis provides powerful support for the Plan’s vehicle and fuel
improvements, the Plan overlooks large public health benefits to
other transportation efficiency measures not in the Plan.

• Public health perils such as obesity, diabetes and heart disease
can be reduced by strategies the Plan should embrace more
aggressively. Auto-dependent neighborhoods make these diseases more
common; smart growth and reduced vehicle miles traveled can help
combat them.

• CARB’s public health analysis needs to address the issue of food
security and “healthy food deserts.” Lacking local healthy food
choices, many people must travel long distances to obtain more
healthy fare or rely on expensive, locally available junk food.
Although emissions benefits of better access to healthy food may be
modest, public health benefits can be significant and climate
change policy offers a chance for low-income “food deserts” to get
attention.