Comment Log Display

Dear Chairman Nichols and Members of the Board:

I am writing on behalf of both myself and my deceased husband, Carl
Moyer, who, as you remember, worked tirelessly for many years for
clean air in California. 

I am excited to see that the California Air Resources Board (CARB),
is moving forward on implementing the Global Warming Solutions Act
(AB 32). As the overwhelming defeat of Prop 23 this last November
showed us, the public is ready for California to take the necessary
steps to reduce our contributions to climate change.

While I agree with many of the steps outlined in the AB 32 Scoping
Plan, I am concerned by the over-allowance of free pollution
credits to the industrial sector in the Cap & Trade Design. I urge
you to revisit, revise, and phase out free allocation to the
industrial sector. The proposed level of free allocation to the
industrial sector is likely much higher than is needed to combat
leakage. Several research studies have found that the “leakage”
claims of the industrial sector are exaggerated and subsidizing
these industries through free allowances creates barriers to
transitioning to a cleaner economy. CARB should build in an
explicit adaptive management process to adjust the free allocation
to the industrial sector based on specified evaluation metrics.

Please take advantage of the favorable public climate that
California currently enjoys around addressing climate change and
implementing AB 32 by taking much-needed bold actions and removing
the massive allowance giveaways outlined in the current rules.
Thank you so much and happy holidays,
Birgitte