Comment Log Display

Dear CARB,

Thank you for your ongoing work to implement California｡ｦs
landmark global warming law, AB 32.

As you know, California is being hard hit by the current economic
crisis.  Californians around the state are losing their jobs, their
homes and the benefits of many state services.  I strongly believe
that the implementation of AB 32 provides us with a unique
opportunity to not only preserve our planet for future generations,
but put us on the path to long-term economic stability &
prosperity.  Vigorous implementation of AB 32 can provide thousands
of green jobs, and establish California as a leader in renewable
energy around the world.

In order to be sure we take full advantage of this opportunity, I
request that CARB adopt a Scoping Plan that will create jobs:

First, please auction off all emission credits. Program revenues
can go toward GHG reduction programs, such as clean technologies,
green jobs, and aid for low-income consumers and small businesses
to reduce their energy bills.  

And please work to reduce the role of offsets in the Plan.
Providing too many offsets encourages continuing emissions in
low-income neighborhoods and in defenseless habitats, and weakens
the demand for clean energy technology and jobs in California. 

To the extent offsets are used, there should be stringent
protocols in place ensuring that the reductions are quantifiable,
new, permanent, subject to independent third-party verification,
enforceable by CARB, and only located in California.  Also, offsets
from sinks, such as planting trees or avoiding tree cut-downs,
should not be allowed at all, since they are too difficult to
measure and often under-perform.

In order to generate robust demand for green energy, I ask that
the Scoping plan also include the following policies:

ボ Ensure cap-and-trade is just a minor tool among market
mechanisms. Other tools should be brought forward more robustly,
including feed-in tariffs and carbon fees in the Plan's near-term
action agenda.

ボ Make sure the 33-percent renewable electricity standard by 2020
is given the force of law, either through legislation or regulatory
action.

ボ Promote and enable Community Choice Electricity Aggregation
(CCA) and its potentially powerful GHG reduction potential for
cities and counties.

ボ Give more specificity and amplitude to the goal of electrifying
transportation, especially greatly expanding ZEV numbers (plug-ins
and electric cars) beyond CARB's current low-level projections.

ボ Greatly strengthen the too-modest land use and agricultural
sections of Plan. The Plan greatly underestimates the significance
of methane emissions, by using the 100-year global warming
potential. Over a shorter time horizon, methane accounts for 17% to
perhaps well over 30% of the state's GHGs, rather than the 5.7% in
the 2004 inventory.

ボ Further increase requirements for zero waste and recycling, as
well as Extended Producer Responsibility.

I appreciate the opportunity to provide these comments, and I
thank you in advance for your time and consideration.

D. McPhall