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Comment 66 for Design Comments for the GHG Scoping Plan (sp-design-ws) - 1st Workshop.


First Name: Joshua
Last Name: Stark
Email Address: JStark@npca.org
Affiliation: National Parks Conservation Association

Subject: Comments to the carbon market references in the Draft Scoping Plan
Comment:
The National Parks Conservation Association (NPCA) is America's
only private, non-profit advocacy organization dedicated solely to
protecting, preserving and enhancing the National Park System. 
NPCA was founded in 1919 and has more than 350,000 members and
supporters, including 45,000 members in California.

NPCA applauds the California Air Resources Board and the State of
California in its vital implementation of greenhouse gas
reductions.  As in many cases, the actions of this great state
formulate policy for the rest of the nation, and hopefully, the
world, and so it is vital that the implementation of AB 32 first
be effective in reducing greenhouse gas emissions.  In this
spirit, the National Parks Conservation Association offers the
following recommendations with regards to the proposed
cap-and-trade market mechanism.

The component of the proposed scoping plan relying on a regionally
organized cap-and-trade market program and expected to create the
largest reductions is also by far the most controversial
component.  Should CARB adopt this plan, NPCA believes that any
carbon market, in order to successfully combat climate change,
must include the following:

1.  Offsets must be auctioned:  

Allowances, offsets, credits – whatever their name, must not be
given away.  Initial GHG offsets must be bought in an auction,
with the proceeds to go directly to combating the effects of
climate change on disproportionately affected areas, including
habitat and resource protections and disadvantaged communities.  

As we have seen, our natural resources are bearing the brunt of
climate change.  With most reputable models showing California
becoming hotter and drier, the potential for catastrophic fires
and major changes to the many ecological niches in California are
quickly becoming reality.  In California’s national parks, major
glaciers are disappearing, and iconic species like giant sequoias
and Joshua trees are experiencing greater threats.  It is vital
that our species and watersheds be protected, and revenues from an
appropriate offset auction can help to mitigate the effects we have
had on our climate.

In addition, disadvantaged communities within California should
benefit from any funds created through an appropriate and
effective offset auction.  As our state becomes hotter and drier,
poorer and rural communities, including gateway communities to
many of our national parks, also experience disproportionate
impacts.  Lower income and rural communities often have older
energy grids and fewer ways to keep warm, and with the growing
outcry for water metering, will find it harder to acquire clean
water sources.  To help mitigate the effects of power outages
during heat waves and less clean water, proceeds from an effective
offset auction should, in part, be allocated to disadvantaged
communities.

2.  Specific greenhouse gas reductions must occur in California,
while maintaining consistency with the mission of the Air
Resources Board:  

AB 32 is a state regulation requiring the reduction of
California’s emissions to 1990 levels by 2020.  This law should
not be superceded by a regional market agreement.  In order to
adequately adhere to AB 32 requirements, and in order to reap its
greatest benefits, any participation by California in a
cap-and-trade market must result in specific reductions in GHG
emissions within the state.  Should CARB adopt a model which does
not guarantee in-state reductions to meet AB 32 requirements,
there exists the unfortunate possibility of tying up any
implementation in unnecessary court battles, due to noncompliance.
 Instead, California’s participation in any regional market should
take place parallel to AB 32 requirements.

One possible way to ensure actual carbon reductions within the
state may be for CARB to develop accurate measurements for
institutions participating in a market scheme, and to develop
incentives for reducing emissions through a market, while not
relying directly on the market model as the source for reductions
in GHG emissions.

It is also vital that any cap-and-trade scheme maintain
consistency with the mission of the California Air Resources
Board.  Co-benefits to greenhouse gas reductions are not merely an
important positive externality to an effective cap-and-trade
scheme; they are also central to the mission of the Air Resources
Board.  By ensuring specific reductions to emissions within the
state, California will reap the benefits of curbing carbon by also
curbing health-damaging pollutants.  

There exists in carbon market schemes the potential for offsets
and credits to actually increase pollution within the state. 
Ensuring the appropriate and true footprint of proposed
developments can go a long way toward eliminating this
possibility.  

Overall, NPCA is concerned that the Air Resources Board has put so
much emphasis on reducing California’s greenhouse gas emissions in
a market scheme that has not yet been created. This market is
still a set of ideas in its infancy, with many potential new
players yet to join, and with so much still unfinished. 
California has only 12 years to reach its legal requirement, a
requirement lacking in other states, provinces, and territories. 
It is possible for California to attach its goals to a larger
group, only to see those goals thrown out by ensuing deals.  If
this were to occur, California would still need to meet its legal
mandate.  NPCA encourages the Air Resources Board to develop
additional measures to meet AB 32 requirements with the
understanding that any deals made regionally, nationally, or
internationally may not meet the legal requirements of AB 32.

Attachment:

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Date and Time Comment Was Submitted: 2008-08-01 13:32:26



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