Comment Log Display

California is blessed with a beautiful natural environment and as a
California I am proud to be part of a state that attempts to
balance economic activity with environmental protection. 
California's geography also burdens the Los Angeles Valley and the
Central Valley with some of the worst air pollution in the United
States.  In addition to the wealth generation aspects of energy
efficiency and renewables, CARB's GHG scoping plan has the
significant co-benefits of reducing criteria air pollutants in
addition to reducing GHGs.   
I am supportive of option 1, direct policy activities to reduce
emission of GHG's.  I am concerned that Cap and Trade mechanism can
be gamed or result in unintended consequences such as those
outlined by the comments from Friends of the Earth (see
https://www.arb.ca.gov/lists/com-attach/38-scopingplan2030-ATBXZld7UjNQewk8.pdf).
 
I am also concerned that California's miss out on the significant
co-benefits from GHG reductions when these reductions are no longer
real reductions in state but are potential reductions out of state.
 I would like to alert this board the findings of the research
brief: "A Preliminary Environmental Equity Assessment of
California’s Cap-And-Trade Program" by authors from UCB, USC, USF
and Occidental College which indicates that 76% of the Cap and
Trade offsets were out-of-state.  (See
http://dornsife.usc.edu/assets/sites/242/docs/Climate_Equity_Brief_CA_Cap_and_Trade_Sept2016_FINAL2.pdf
). Almost half of these offsets were for forestry projects. (See
figures 7 and 8 in the report).  
Really reducing air emissions in California provides health and
amenity benefits co-benefits that are not quantified but result in
a "no regrets" approach to reducing GHGs.  Limiting trade-offs to
within California would increase the cost of emission credits and
provide more incentive to directly reduce emissions instead of
paying for credits.  Some of the largest emitters in the state are
located next to disadvantaged communities and thus direct
reductions have an added benefit of environmental and social
justice. 
If CARB is set on maintaining Cap and Trade, I recommend they limit
the scope in which sectors are covered and limit the geographical
range to California.
Overall I am supportive of CARB's scoping plan and the
corresponding efforts taken by the state legislature (i.e. SB 350)
to lead on how GHG's can  be reduced while having a thriving
economy.  Hopefully this is a plan that can be exported to other
states and the rest of the world.