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Comment 210 for AB 32 Scoping Plan (scopingpln08) - 45 Day.

First NameErin
Last NameRogers
Email Addresserogers@ucsusa.org
AffiliationUnion of Concerned Scientists
SubjectClean Tech Business Letter in Support of Limiting Offsets
Comment
Clean Tech Statement of Support: 
Limiting Offsets & Prioritizing Clean Energy in a Western Regional
Cap and Trade System

WHERAS:
Western States’ Electricity GHG Reductions Could Come from Offsets
Instead of Renewables: The Western Climate Initiative (WCI)  is
recommending a regional, multi-sector global warming cap and trade
program that would allow the electricity sector and other capped
emitters to use offsets to substitute for up to half of the direct
emission reductions they otherwise would have been required to
make. The WCI will not approve offset credits for global warming
emission reductions that come from renewable energy projects in the
US or other developed countries. 

Offsets Could Drain Funding from Renewable Energy: A significant
use of compliance offsets in a cap and trade system will likely
drain potential new flows of capital away from renewable energy and
other clean tech global warming solutions in high-emitting, capped
sectors such as electricity.  Limiting offsets, on the other hand,
can help direct new capital toward clean tech solutions and other
emission reduction efforts in these sectors by encouraging
utilities to purchase renewable energy instead of dirtier energy
sources that will become more expensive due to higher carbon
prices.

Limiting Offsets Make Renewables More Competitive: Limiting
offsets will maintain demand for carbon emission allowances, thus
helping to maintain a meaningful allowance price, which should in
turn increase the profitability of currently available low-carbon
technologies and encourage the development of new clean tech
options. 

Limiting Offsets Incentivizes Utility Purchases of Renewable
Energy: By maintaining a robust carbon price and concentrating
emissions reductions in capped sectors, limits on offsets will
provide another reason for utilities and publicly-owned utilities
to purchase renewable energy above and beyond their existing
renewables purchase obligations. 

Cap and Trade Should Support Renewable Energy: An effective
regional cap and trade system should directly account for and
reward the global warming emission reductions resulting from
voluntary renewable energy generation by retiring carbon allowances
on behalf of voluntary renewable power produced in the region, and
encourage development and deployment of renewable energy through
the appropriate use of the value of allowances.

STATEMENT OF SUPORT:
The signatories below encourage the states and provinces in the
Western Climate Initiative to ensure that a regional cap and trade
program bolster the development and deployment of renewable energy
sources in the region and limit the amount of compliance offsets
allowed in any global warming cap and trade system to a small
fraction of the emission reductions that the program seeks to
achieve.

         SUPPORTERS

Businesses & Organizations
Ausra, Inc.  
Holly Gordon

BrightSource Energy 
Joshua Bar-lev

California Wind Energy Association 
Nancy Rader

CEERT 
Rachel McMahon

Cleantech America, Inc. 
Ben Barnes

Climate Earth, Inc. 
Chris Erickson

Environment & Enterprise Strategies 
Holly Kaufman

enXco Development Corporation 
Mark Tholke

Fat Free Biofuel
Shannon Devine

GreenVolts, Inc. 
Craig Lewis

Large-Scale Solar Association 
Shannon Eddy

Leading Change Consulting 
Steve Levin

New Voice of Business  
Elliot Hoffman

Recurrent Energy 
Arno Harris

Solaria 
David Hochschild

SolFocus 
Kelly Desy

Stirling Energy Systems
Bob Liden

Sungevity 
JP Ross

Suntech 
Polly Shaw

Sustainable Energy Partners LLC 
John Humphrey

S3: Sustainable Solutions Systems 
Shripal Shah

Vote Solar 
Adam Browning
	
Individuals
Dan Kammen UC Renewable and Appropriate Energy
Laboratory,Technical Board Member, UCS

Oliver Bock
Clean Tech Investor

William Coleman
Mohr Davidow Ventures	

Attachment www.arb.ca.gov/lists/scopingpln08/726-clean_tech_offsets_letter_11-21.pdf
Original File NameClean Tech Offsets Letter 11-21.pdf
Date and Time Comment Was Submitted 2008-11-21 15:43:20

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