Comment Log Display

Chairman Nichols and Members of the Board:
Your work as part of the California Air Resources Board (CARB)
implementing the Global Warming Solutions Act (AB 32) is critical
to the health of our state, its people, and its plants and animals.
 Now is the time for bold action.
While I agree with many of the steps outlined in the AB 32 Scoping
Plan, I am very 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.
With the resounding defeat of Prob 23, you have a mandate to take
the much-needed and critical actions and removie the massive
allowance giveaways outlined in the current rules. Thank you.