Comment Log Display

    Chairman Nichols and Members of the Board:

    I am happy to see that the California Air Resources Board
(CARB), is moving forward on implementing the Global Warming
Solutions Act (AB 32).  California is once again leading the
country on environmental issues and the rest of the nation will be
watching us as we implement this landmark law. 

    While I agree with many of the steps outlined in the AB 32
Scoping Plan, I am concerned by the over-allowance of free
pollution credits to the industrial sector in the Cap & Trade
Design. I urge you to revisit, revise, and phase out free
allocation to the industrial sector. The proposed level of free
allocation to the industrial sector is likely much higher than is
needed to combat leakage. Several research studies have found that
the “leakage” claims of the industrial sector are exaggerated and
subsidizing these industries through free allowances creates
barriers to transitioning to a cleaner economy. CARB should build
in an explicit adaptive management process to adjust the free
allocation to the industrial sector based on specified evaluation
metrics.

    Please take advantage of the favorable public climate that
California currently enjoys around addressing climate change and
implementing AB 32 by taking much-needed bold actions and removing
the massive allowance giveaways outlined in the current rules.
Thank you.