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