Comment Log Display

Chairman Nichols and Members of the Board:

I heartily support the California Air Resources Board (CARB)efforts
to move forward on implementing the Global Warming Solutions Act
(AB 32). With overwhelming defeat of Prop 23 this last November
showed us, the public wants California to take the necessary steps
to reduce our contributions to climate change.

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. I AM
PARTICULARLY INTERESTED IN BEING SURE THAT NEW CONSTRUCTION
PROJECTS SUCH AS AT THE PORT AND ANY MAJOR ROAD CONSTRUCTION AND
TUNNELS ADHERE TO THE HIGHEST STANDARDS. THESE ARE OFTEN MASSIVE
PROJECTS EXTENDING OVER YEARS WITH HUGE IMPACT.  ALSO IF PROJECTS
CONTRIBUTE TO INCREASED TRAFFIC, THAT SHOULD BE ACCOUNTED FOR
(INDUCED CONGESTION). 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.