Comment Log Display

Chairman Nichols and Members of the Board:

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.

Although I agree with many of the steps outlined in the AB 32
Scoping Plan, I am greatly 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.