Comment Log Display

June 7, 2010

Mr. Kevin Kennedy 
Office of Climate Change	
California Air Resources Board
1001 I Street
Sacramento, CA 95814

RE: Greenhouse Gas Cap-and-Trade Regulation:  Ensuring an
Equitable and Sustainable Implementation for California’s Workers
and Residents

Dear Mr. Kennedy,

We thank you and your staff for the detailed update on the status
of the Cap-and-Trade Regulation on May 17, 2010, and for providing
us with an opportunity to share our feedback. 

Green For All is a national organization working to build an
inclusive green economy strong enough to lift all people out of
poverty.  Our organization proudly works with leaders in civil
rights, faith, labor, environmental, and community groups in
shaping and winning green jobs legislation at the federal, state,
and local levels across the country.  We are submitting comments
because California’s cap-and-trade program will have significant
impact on the future of our nation.     

California’s policies directly affect policymakers in other
states and at the federal level.  California’s adoption of
low-emission vehicle standards, for example, has led to other
states and the U.S. legislature adopting similar policies.  Indeed,
President Obama has announced federal support for California’s
stringent standards and noted that the federal government would set
national standards modeled after California. 

California’s leadership in clean energy now has heightened
significance as federal legislators now debate climate legislation.
 As such, we urge you to keep California as the national leader on
issues related to climate change.  We believe the following
provisions are important steps towards that end: 
 
Invest allowance revenues into programs supporting renewable
energy, energy efficiency, and low-income consumers.   California
should build upon and learn from the Regional Greenhouse Gas
Initiative (RGGI) by investing proceeds generated from allowances
into programs that reduce greenhouse gas emissions, increase
investments into in-state renewable energy and green jobs, and help
low-income consumers mitigate potential price increases and meet
needs through the Community Benefits Fund (as discussed below).  
In particular, it is essential that these funds be invested in
renewable energy projects in California to ensure that our
state’s economy and workers benefit from our environmental
leadership. 

Move the Community Benefits Fund to the “tier one” category of
allowance value flow.  Climate change threatens all people, but it
is impoverished communities who suffer the most.  From heat-related
deaths to floods, lost jobs and air pollution, low income
communities and communities of color are the first to be devastated
when climate disaster strikes.   The Community Benefits Fund will
ensure that communities most vulnerable to climate change will
receive the needed programs to reduce greenhouse gas emissions,
water and energy efficiency, and provide programs to protect
against the rising dangers of climate change.    By capitalizing
the Fund, public support for AB 32 will also increase. 

Include California’s workforce as “impacted stakeholders” in
developing the cap and trade program.   Pursuant to California’s
Health and Safety Code Sec. 3857(b)(3), the Board must “maximize
additional environmental and economic benefits” in the
implementation of market-based compliance mechanisms.   We ask that
the ARB consider California’s workforce in weighing the various
programmatic options for cap and trade.  For example, in the
American Clean Energy and Security Act (ACES), the House of
Representatives added provisions (1) allowing the Secretaries of
Labor and Energy to target employment and training opportunities in
green construction to workers and communities who traditionally
have had little access to career-track jobs with high-road
contractors in the building trades; and (2) providing funds to
training workers facing obstacles to employment for career-track
jobs.  California may look to include similar provisions into its
AB 32 programs.  This ensures that communities most harmed by
climate change will be able to benefit from the economic and
environmental gains that AB 32 aims to provide.   

Thank you for considering these comments.  Please feel free to
contact me directly if you have any questions or would like to
discuss further ideas on how to ensure low-income communities are
protected in climate change mitigation programs.  I can be reached
at vivian@greenforall.org or (510) 271-9830. 

Sincerely,




Vivian Chang
Green For All