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Comment 61 for Public Input on Cap-and-Trade Auction Proceeds (investmentplan-ws) - 1st Workshop.


First Name: Jim
Last Name: Stewart
Email Address: Jim@earthdayLA.org
Affiliation: Earth Day Los Angeles

Subject: Earth Day Los Angeles Input on Investment of Cap-and-Trade Auction Proceeds
Comment:
Earth Day Los Angeles Input on Investment of Cap-and-Trade Auction
Proceeds

The California Air Resources Board has asked for input for an
investment plan for the auction proceeds from the cap-and-trade
program to meet the goals of Assembly Bill 32 (AB 32).

A group of environmental and social justice organizations developed
joint input for the California Public Utilities Commission’s
similar question of how to invest the allowance revenues from the
cap-and-trade program for electricity generation.  The groups
included: Natural Resources Defense Council, Sierra Club
California, The Greenlining Institute, Union of Concerned
Scientists, Local Government Sustainable Energy Coalition, National
Consumer Law Center, Climate Protection Campaign, California
Housing Partnership Corporation, and Community Environmental
Council.

Attached are the initial and reply comments jointly submitted by
these groups in the CPUC proceeding R. 11-03-012, along with the
Appendices and Exhibits.  Although not all the details relate to
the Air Resources Board, many of the main points do apply,
including prioritizing investment in three broad categories: (1)
expanding energy efficiency programs, including developing
innovative financing strategies to support emerging clean energy
technologies and implementation strategies; (2) expanding low and
moderate energy efficiency programs; and (3) enabling better
interconnection, integration and support for distributed renewable
generation.

The environmental and social justice groups’ proposal also
highlights a series of carbon mitigation activities facing market
barriers that auction revenues could help address, and identify
opportunities to supplement current programs to capture additional,
untapped energy savings.

The proposal also asked that investments under each strategy are
additional to programs and expenditures otherwise necessary to meet
existing legal and regulatory requirements, prioritize investments
in California’s most impacted and disadvantaged communities and
non- commercial entities that provide vital social services such as
local governments, schools, universities, hospitals, federal and
agencies, and community-based organizations.

In addition, implementation should facilitate customer
understanding, engagement and support for California’s climate
programs.  For example, any revenues to individuals (including low
income households) should be in the form of a separate off-bill
rebate, not merely deducted from their bill.

Included in the attached zip file are the following:
Revised Proposal, filed 1-6-12
Opening Comments, filed 1-31-12
Reply Comments, filed 2-14-12
Of particular interest are the many footnoted references, plus the
Appendices and Exhibits: 
Appendix A: Disproportionate Impacts of Climate Change on Low
Income Households 
Appendix B: Illustrative Local Government Programs 
Appendix C: Expanded Multifamily Residential Energy Efficiency
Programs
Exhibit 1: The Climate Gap – Inequalities in How Climate Change
Hurts Americans and how to Close the Gap
Exhibit 2: Climate Change, Extreme Heat, and Electricity Demand in
California 
Exhibit 3: Pie in the Sky? The Battle for Atmospheric Scarcity
Rents
Exhibit 4: Cap and Dividend: How to Curb Global Warming While
Protecting the Incomes of American Families
Exhibit 5: Clear Economics: State-Level Impacts of the Carbon
Limits and Energy for America’s Renewal Act on Family Incomes and
Jobs
Exhibit 6: Schools of the Future Report
Exhibit 7: Improving California’s Multifamily Buildings:
Opportunities and Recommendations for Green Retrofit & Rehab
Programs
Exhibit 8: Investment of Proceeds from RGGI CO2 Allowances

Attachment: www.arb.ca.gov/lists/investmentplan-ws/69-enviroejgroupproposals.zip

Original File Name: EnviroEJGroupProposals.zip

Date and Time Comment Was Submitted: 2012-06-22 08:06:53



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