Comment Log Display

The investment plan should incorporate the following points.  More
detailed comments are provided in the attachment.
1. The list of potential uses of funds should be expanded to
include the return of auction proceeds to households and/or to
offset business taxes.  
2. The Governor and the Legislature should establish on a policy
basis the aggregate amount of funds to be allocated to short term
projects, long term projects, and the return of auction proceeds to
households and/or to offset business taxes.  Proposals should
compete within each category but not across categories.
3. To minimize the potential for legal challenge all funded
projects (other than the return of funds to households or
businesses) should result in greenhouse gas reductions. 
4. In general auction proceeds should be used to reduce overall
compliance costs rather than achieve additional reductions beyond
those identified in the Scoping Plan.
5. Funding to support near-term reductions (a) should only address
emissions from sources not covered under the cap, or sources under
the cap that do not respond to the price signal imposed by the cap,
(b) should be prioritized based on cost-effectiveness, and (c)
should only be provided to projects that achieve reductions at a
cost per ton lower than the allowance value (except as modified for
SB 535 purposes as noted in the attached detailed comments). 
Reductions from sources not under the cap should be treated as
offsets, or alternatively additional allowances should be created
within the cap in an amount equal to the reductions achieved from
the uncapped sources.
6. Long term strategies should focus on transport electrification,
VMT reduction/land use, and energy efficiency/renewables, and
should be evaluated on the basis of return on investment
(cost/benefit analysis), taking into account the full range of
societal and private benefits accrued.