| Comment | California Air Resources Board
1001 I Street
Sacramento, CA 95812
RE: Proposed Cap & Trade Regulations
Dear Chair Nichols, Board and Staff:
Thank you for your hard work and leadership in this arena. As a
former long-time constituent and supporter of Fran Pavley, it is
gratifying to see this policy coming to fruition.
First, as a new staff member of the Climate Protection Campaign, I
want to concur with the CPC’s main points, contained in separate
correspondence from our Executive Director, Ann Hancock, in favor
of:
• An upstream-biased system
• Initial maximization leading to 100% auction of permits
• Compensating ratepayers with a dividend
• Use of trading proceeds to fund important energy efficiency and
renewable energy programs
• A price floor on allowances (which is included in the proposal at
$10.00/allowance)
I want to emphasize the point about specifically defining ratepayer
benefit. Currently the benefit is not defined at all. This should
be a rebate check sent to ratepayers separately from their utility
bill so that they receive the price signal first and financial
adjustment secondarily.
In addition to the above, I support:
• The declining cap;
• The full auction of allowances in the transportation sector;
• The concern among my fellow Sierra Club volunteers and others
about the regulations allowing forest clear-cut offsets. Please
eliminate this provision from the regulations.
Thank you for the opportunity to comment,
Woody Hastings
Sebastopol, CA
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