Comment Log Display

Mary Nichols
Chair, California Air Resources Board
Sacramento, CA  95814

Bay Area Council Updated Comments on AB 32 Draft Scoping Plan
(Please see attachment for full discussion of Scoping Plan)

Dear Chair Nichols:

The Bay Area Council appreciates the opportunity to provide
comments on the proposed scoping plan recently released by the
California Air Resources Board.  We applaud the greater emphasis on
the role of land use to reduce greenhouse gas (GHG) emissions, and
the recognition that local governments are essential partners in
the fight against global warming.  

More than doubling the land use goal, from 2 MMTCO2 to 5 MMTCO2,
is an important step forward, and with that as an objective, we
recommend that the Cap and Trade on Greenhouse Gas Emissions be
implemented with urgency in conjunction with the Western Climate
Initiative.  The Cap and Trade Market will provide an economic
incentive for emissions reduction and the reduced costs for market
participants can further innovation and technology implementation
to reduce energy use and emissions.

The recommendations on implementing the Low Carbon Fuel Standards
and reducing emissions of future cars taken together will drive the
innovation necessary to meet the 2050 reduction target.

The draft scoping plan reduces the local government reduction
target from 2 MMTCO2 in 2020 in the draft scoping plan to zero in
the Proposed Scoping Plan.  The ARB should re-consider providing
reductions from local governments in their accounting or sector
specific policies by including real tools, mandates, incentives –
including offset project credits for those reductions outside of
the cap and trade program - and specific guidelines that will help
local governments enforce and scale up existing efforts, thereby
enabling them to act as allies in statewide GHG reductions. 

The Bay Area Council comments on supportive actions are broken
into applicable sections and are as follows:  Overview, The Goals,
Mandatory Reporting, Implementing a Cap and Trade System,
Coordinate Investments in Clean Tech and Energy Efficiency,
Relevant Fee and Public Goods Charge in Transportation and Water,
and Early Action Credit.

Be well,

Andrew Michael
Vice President Sustainable Development
Bay Area Council