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Comment 22 for Low Carbon Fuel Standard - General (lcfs-general-ws) - 1st Workshop.
First Name: Stephen
Last Name: Rush
Email Address: SLRush@ForFuelFreedom.com
Affiliation: For Fuel Freedom, Inc.
Subject: Cap & Trade Planning & Regulation Recommendations
Comment:
Recent reports by certain fiscal oversight organizations and corporations (such as PGE) speak of Cap & Trade as a bad idea that will only overburden the electric power consumer. Not exactly true. The net effect of Carbon tax / Cap & Trade - if the program is written well and well thought out - will be a good investment on the part of the taxpayer/consumer without being overly burdened through energy cost savings in time and will help energy companies not merely manage their emissions but earn profits while being environmentally conscious. As CEO of a bio-fuels and technology company, and as an informed leader in the industry, there are many companies large and small that are looking forward to incentives and putting pressure on power plants and industrial centers to clean up their air. Despite the cost to the taxpayer and consumer initially, if this is done right will generate jobs, help stabilize the economy, and eventually reduce costs to the consumer. However, many technology companies that can perform this function are small businesses that have scaled back their workforce recently, leaving the core of their business workload to the executives and utilizing personal credit to keep their business alive. So whatever the plan that is put into place, it must account for the current economics, and my first recommendation is to waiver permitting and fees up front, but to be recaptured in taxes. With this in mind, the bill would work to create energy jobs if carbon trade is specifically written as an investment into carbon-reducing development and expansion by companies that have anything to do with renewable fuels, sequestration, solidifying, or any such process. There are economic benefits of scrubbing CO2, since it can be used as oil extraction, deep freeze, cleaning solvent, and making algae for use as bio-diesel or high-grade jet fuel. Each company has varying technology and profitability from the next, but the important thing is making that CO2 available. My second recommendation for these carbon development monies is to legislate that commodity traders must provide carbon trading brokering services when necessary, and that the cost of exchange is reasonable and is absorbed by the producer of carbon or a maximum of 3% gross profit of the user. But that is not the only consideration. The bill would work to create energy jobs if there is a carbon tax for significant expulsion of pollutants over a certain amount, or non-compliance, and preferably that tax will increment quarterly. Without a financial burden to motivate companies to look around the various markets for profitable technologies so that they can make up the difference for the cost to capture / sequester and utilize that carbon, then that CO2 would be hard to force them into looking at other forms of energy. My third recommendation then is to legislate that there be a carbon tax of around $137 per ton of CO2 or $1,300 per MW if none of these technologies are used. If carbon generation sources do wish to utilize a carbon capture technology, then might I suggest the carbon “waiver” paid directly to the technology company in the amount of $77 per ton of CO2 or $730 per MW, and a minimum of 33% of the total must go toward companies with technology in some phase of development but not fully commercialized. (To give an idea, the cost to store CO2 is approximately $165 per ton, yet the profit for our algae system is between $10 to $30 depending on transportation costs once constructed but our capital costs are roughly $595 per MW.) Because technology companies may not allocate 100% to a fully functioning facility, they must reserve or grant 15% to a participating company to encourage such future building projects through a facilitated pool. The bill would work if there was a review process to ensure inclusion of every American company that wanted to participate. So, my next recommendation is make exemptions for participants to deviate from previously established program requirement laws, in addition to the above recommendation. For example, the development and technology companies must qualify by hiring mostly in California for this project, and if there are any program bids they must be shared by percentage of the dollar amount of the next lowest bid so all that can stimulate the economy will participate, no matter their stage of development and without grant deadline. America needs to get working again and small business need the free flow of money that comes from a plan such as this. Please give this your most undivided attention. Thank you. Stephen L. Rush, CEO For Fuel Freedom, Inc. Inland Empire, CA 92399 (909) 213-2750 (direct) SLRush@ForFuelFreedom.com
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Date and Time Comment Was Submitted: 2009-10-12 14:29:53
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