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Thank you for accepting these comments on the Proposed First Update
to the Climate Change Scoping Plan. ARB has the opportunity to
improve the California program by increasing the amount of
allowances auctioned, reducing the free allowances to industrial
emitters, and returning more revenues collected back to households
as a dividend. 

Using funds on large infrastructure projects to reduce emissions
may simply reduce the price of allowances, or change the relative
price of emissions between sectors, but result in no net emission
reduction because the reductions achieved only create space for new
emissions from other sectors under the cap.  In other words, the
space below the cap created by the infrastructure investment is
simply filled up by emissions in other sectors.  A better use of
funds is to return them to everyone equally, building a statewide
constituency for a carbon price, altering perceptions of people's
relationship to climate change and to each other, and addressing
the regressive impacts of a carbon price.  We are in this together,
and we need an economic system that supports us as we make the
transition.

Please see the attached comments for more information.
Thank you for your consideration.
Sincerely,

Mike Sandler
www.carbonshare.org