First Name | Barry |
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Last Name | Vesser |
Email Address | bvesser@climateprotection.org |
Affiliation | Climate Protection Campaign |
Subject | Changes to CALIFORNIA CAP ON GREENHOUSE GAS EMISSIONS AND MARKET-BASED COMPLIANCE MECHANIS |
Comment | We are very concerned that ARB’s decision to remove the limited restrictions on the investor-owned utilities’ (IOUs) use of allowance value is unwarranted and potentially detrimental to the ongoing process to allocate allowance value in furtherance of the objectives of AB 32. We disagree with ARB’s decision to remove the provisions in the rule providing guidance to the electric IOUs on how to return auction revenue for the benefit of their retail customers, Section 95892(d)(3) page 143 of the revised draft. The provisions simply ensure that the IOUs’ use of allowance value will not mute the carbon price signal embedded in retail rates or be tied exclusively to an individual utility customers’ energy consumption. Maintaining the carbon price at the retail level is at the heart of staff’s allocation scheme for the utility sector and reflects the consensus recommendation of nearly every expert body that has examined the issue - including the Economic Allocation Advisory Committee. As designed, we do not believe that the provisions would unduly interfere with the California Public Utilities Commission’s (CPUC) jurisdiction over rate setting. Although ARB’s rationale to remove the provisions rests on questions of legal authority, we are concerned that stakeholders may attempt to construe ARB’s decision as signaling a change of position on the matter from a policy perspective. Past CPUC decisions have called for ARB’s judgment on questions surrounding allocating allowance value from the electricity sector and ARB’s position will be significant in shaping the ultimate resolution. Should ARB proceed with the proposed changes, we therefore ask that ARB reaffirm unequivocally its expert conclusion that “staff believes that any rebates to residential customers should be made as separate payments and not simply deducted from customer bills. The purpose of this restriction is to ensure the carbon price is reflected in residential electric rates” Thanks for your consideration. |
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Date and Time Comment Was Submitted | 2011-09-27 09:04:56 |
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