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Equity and disproportionate impact issues have been raised by the
environmental justice community. Specific carbon market designs can
address many of these legitimate objections to the Cap and Trade
rule as it was adopted in December of 2010.  Instead of giveaways
to polluting industries, CARB could auction 100% of permits. Rather
than unlimited offsets, CARB can strictly limit the number of
offsets to a minimum.  Inequities in the use of allowance value can
be addressed with a Cap & Dividend approach that returns revenues
back to all Californians equally.  Please incorporate these
elements into the environmental analysis.

Thanks for your work on this important issue.

Barry Vesser
Climate Protection Campaign