Comment Log Display

On behalf of Save Our Peninsula Committee please find the
following:
   Save Our Peninsula Committee opposes the proposed amendment.  I
refer to research work undertaken by Danny Cullenwood and David
Weiskopt in a recent
Stanford Law School working paper.  The paper shows that the
Board's exemptions will permit rampant resource shuffling, which
could result in leakage tht exceeds the cumulative mitigation
required under the cap-and-trade market through 2020.  Prior to
consideration of proposed amendment, an EIR should be undertaken
to
assess the environmental impacts of the proposed amendment.

Thank you for consideration of this matter

Richard H. Rosenthal
for Save Our Peninsula Committee