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Ms Nichols,

I am writing regarding the AB32 Scoping Plan which is being
developed by CARB and will be issued soon.  This Plan is extremely
critical to significantly decrease California's production of
greenhouse gases.  Global warming is already progressing more
rapidly than before and snail pace action or no action is simply
not an option. 

Three factors should be included in the plan.

One is a cap and trade program.  This would put a ceiling on the
amount of gases produced.  As many sources of gases should be
under the cap and trade program so that we can reach a goal of 80%
coverage by 2020.

Second, is an Indirect Source Rule.  We cannot ignore any source
of gases.  Those gases produced by construction vehicles, delivery
vehicles or even tilling the soil need to be included in the amount
ascribed to a project. 

Finally, we need a robust Renewal Energy Profile that would
dramatically increase the amount of renewable energy that utility
companies would have to provide.  The CARB's preliminary statement
of 33% by 2020 is a minimum.

Without these components the program risks being too weak to
combat global warming.  California needs a strong program.