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Comment 57 for Design Comments for the GHG Scoping Plan (sp-design-ws) - 1st Workshop.


First Name: Garrett
Last Name: Fitzgerald
Email Address: gfitzgerald@oaklandnet.com
Affiliation: City of Oakland

Subject: Comments on Program Design
Comment:
Below are comments from the City of Oakland specific to Proram
Design related to the Draft Scoping Plan. These comments were also
included in the City of Oakland's letter submitted to the General
Comments section of this website.

1. Economic Analysis on Low-Income Communities Needed
The Plan references an economic analysis being conducted of
potential impacts on low-income communities due for release in
Summer 2008. The City of Oakland are very interested in this
analysis and the potential impacts of the Plan on low-income
residents of our community. In particular, we are interested in
evaluations of the potential cost impacts that may be passed to
residents/consumers through electricity and fuel surcharges, along
with any programmatic fees that might be levied through other
avenues. We have significant concerns that low-income residents
may be disproportionately affected by these costs due to
relatively low ability to pay, and urge that specific actions be
taken to help offset these disproportionate effects.

2. Revenues Should be Invested via Local Governments to
Cost-Effectively Reduce Additional GHGs, Increase Resilience to
Climate Change, and Green California’s Economy 
Page 45
We strongly support the suggestion that a portion of program
revenues should be invested in the form of “funding or other
incentives to local governments for well-designed land-use
planning and infrastructure projects [that] can do much to
discourage long commutes and encourage walking, bicycling and use
of transit.” Local governments, working independently and in
collaboration with regional partners, have significant leverage in
fostering vehicle trip reductions, a critical component to reducing
transportation-related GHG emissions. Reducing vehicle miles
traveled throughout the state will be critical not only to
achieving the AB 32 goals but also the Governor’s stated goals of
reducing GHG emissions by 80% by 2050.

In addition, a portion of revenues should be targeted toward
making specific transit and other infrastructure improvements in
low-income communities, and potentially toward augmenting
traditional low-income weatherization and bill assistance-style
programs to help offset the disproportionate effects of
program-related costs on low-income communities.

A portion of revenues should also be invested in helping local
governments to develop climate adaptation/resilience plans to help
local communities best increase resilience to the ongoing,
developing effects of climate change that are already happening.

Finally, a portion of funds should be invested in workforce
training to prepare workers for green jobs. These funds should be
concentrated in areas where a significant number of workers can be
engaged.

3. Do Not Rely Exclusively on Cap and Trade 
A system that relies exclusively on Cap and Trade could postpone
investment in next generation technology. Coupling Cap and Trade
with fees levied upon polluters to insist on minimum performance
will allow more regulatory oversight and establish a floor price
for carbon in the state. Results can be more comprehensive across
technologies and challenges as regulators require progress on
specific technologies to develop lower polluting alternatives on a
specific time schedule. ARB should also consider imposing
disincentives on ‘leakage’ (see Section 2B.1) to areas outside the
WCI territory. 

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2008-08-01 10:41:38



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