Comment Log Display

Move San Diego is a non-profit organization working to create
convenient, on-time, healthy, sustainable transportation
throughout the San Diego region.  Currently, our major focus is
working with business, environmental, and government interests to
create a transit system which is competitive in every way with
private automobiles, and to reform land use planning to emphasize
compact development conducive to transit, bicycling and walking. 


Move San Diego has reviewed the Climate Change Draft Scoping Plan
and are pleased to submit the following comments.

First, we are pleased to see that the Air Resources Board takes
very seriously the ambitious timelines laid out in AB 32.  It
appears regulations and programs will be in place in a timely
manner as prescribed by the law.  We also commend ARB for due
consideration of co-benefits of GHG regulation and the need to
avoid disproportionately large impacts on underrepresented
populations.

The Cap and Trade Approach

We agree with the document’s basic framework, which entails the
creation of a new cap and trade system for GHG, managed in
cooperation with the other state members of the Western Climate
Initiative.  This seems the most sensible approach.  We urge you
to consider every aspect of the launch of the cap and trade
system, such that polluters do not receive windfall profits, at
the expense of consumers, and that any revenues from the system be
used in part to reduce the costs to members of the public most
disadvantaged by increased prices that may result from regulation.
 This can best be accomplished by auctioning allowances or credits,
and distributing these revenues to low income groups via public
transit enhancements, needs-based rebates on high-efficiency
appliances, etc.

2020 vs. 2050 Focus 

The attention of the Plan is focused almost exclusively on the
2020 greenhouse gas (GHG) reduction target of approximately 30%
reduction from business as usual, ignoring the 80% reduction below
1990 target for 2050.  Very few places in the Plan is there
consideration of launching initiates that will have a small
benefit by 2020 but a substantial benefit by 2050.  This is a
significant oversight, as it especially undervalues the slow,
steady and possibly irreversible increase in emissions resulting
from low density sprawl development.