Comment Log Display

Chairman Nichols and Members of the Board:

I am glad to see that the California Air Resources Board (CARB), is
moving forward on implementing the Global Warming Solutions Act (AB
32). 

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, lower, and phase out free allocation to the industrial
sector. The proposed level of free allocation is 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 and implement
AB 32 with bold actions, and remove the massive allowance giveaways
outlined in the current rules. Thank you.