Comment Log Display

RE: 2030 Target Proposed Scoping Plan

Dear CARB and other stakeholders,

Thank you for the opportunity to comment on the CARB 2030 Target
Proposed Scoping Plan.

Californians for a Carbon Tax (CalFACT) is a grassroots,
citizen-led effort to promote equitable, efficient, and effective
carbon pricing in California. 

CalFACT supports the efforts of the of the Environmental Justice
Advisory Committee and the Environmental Justice community and has
signed on to their Declaration in Support of Carbon Pricing Reform
in California.

We applaud CARB for considering multiple options for carbon pricing
in the Proposed Scoping Plan. We think it is critical for all
California legislators and stakeholders to have enough information
and analysis to adequately compare the available carbon pricing
options.

We believe that a steadily rising carbon tax would provide the best
carbon pricing mechanism for California to meet its climate
reduction goals for 2030 and 2050. 

A carbon tax implemented as far upstream as possible can cover
emissions from fossil fuels throughout the economy. A predictable,
annually-rising carbon price that is embedded in the price of all
goods will motivate consumers to reduce costs, which will in turn
reduce emissions. Even more, it will motivate investors and
businesses to make the short- and long-term investments in
infrastructure that will transition our economy towards sustainable
clean energy.

We also believe that rebating a significant portion of the revenue
from a carbon tax to California households is essential to its
success. Not only would a rebate protect low-income and vulnerable
populations from price increases, but it would maintain political
support for the program even as the carbon price increases to the
level needed to reach our emissions reduction targets. Furthermore,
such a rebate will both stimulate the economy and create local jobs
as people spend their money in their local communities.

Attached we offer a supplement to the information you provide on
the Carbon Tax Alternative. We hope that you will incorporate these
concepts into the next version of the Scoping Plan. First, we
provide additional criteria by which we think the scoping plan
scenarios should be evaluated. Then we provide an alternative
version of Alternative 2: A Carbon Tax, so that it presents a more
complete picture of what an effective carbon tax alternative might
look like for California. 

We also encourage CARB to include greater analysis of the
effectiveness of the current cap-and-trade program in California,
as well as cap-and-trade in the European Union and in the
Northeast, under the Regional Greenhouse Gas Initiative. Recent
analysis shows that the primary emission drivers in those areas
have not been cap and trade but: (1) the economic recession of 2009
and long-term shifts in economic structure, such as the decline of
manufacturing; (2) impact of “complementary” regulatory programs
that encourage or even mandate renewables and energy efficiency,
which undermine cap and trade; and (3) structural changes in energy
economics—the expansion of the production of natural gas, which is
displacing coal in the electric generation market, and the ongoing
rapid decline in renewable costs. 

We provide a detailed analysis on some of the challenges of
cap-and-trade in Appendix 1.

We also provide additional information on the effects of British
Columbia’s Carbon Tax in Appendix 2.

In the interest of providing the most complete and even-handed
analysis to the California legislature and the public as you revise
the Scoping Plan, leading to sound public policy, we ask you to
consider this input. 

Thank you again for this opportunity to engage in this process and
for all of your work in helping California meet our climate goals.


Tony Sirna
Valerie Bane
Olivia Angus

For Californians for a Carbon Tax (CalFACT)
www.calfact.org

calfact@calfact.org