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Comment 42 for Scoping Plan Update: The Proposed Strategy for Achieving California's 2030 Greenhouse Gas Target and Draft Environmental Analysis (scopingplan2030) - Non-Reg.

First NameDaniel
Last NameBrotman
Email Addressdhbrotman@gmail.com
Affiliation
SubjectCap & Trade vs. Carbon Fee
Comment
I attended the ARB/EJAC meeting in Los Angeles on March 15.  I was
disappointed to see how the ARB presenters wrote off the
alternative of a carbon fee without a clear rationale. They were
unable to address questions on the economic assumptions that they
based their conclusions on to decide that a fee would be less
effective than cap and trade.

I would like to see the ARB do a transparent comparative analysis
in which the public can understand the model assumptions and make
comments. I am an economist (teaching at Glendale College) and I
can see no economic logic to argue that cap and trade is superior
to a fee. Virtually all economists believe a fee is cheaper to
administer and more transparent that cap and trade, and if the fee
is set at the right level can deliver more GHG reductions for the
same cost than cap and trade. To the extent that your analysis
reaches a different conclusion, the assumptions must be skewed to
arrive at a politically predetermined conclusion. This is no way to
make public policy.

A fee structure in California would provide a model for national
level legislation. Ultimately, that is where we need to go for us
to make a meaningful impact on climate change. Furthermore, a fee
(coupled with the right direct regulations) would create greater
cost certainty for industry and insure a more predictable income
flow to the state for application to climate justice initiatives.

Attachment
Original File Name
Date and Time Comment Was Submitted 2017-03-21 15:16:12

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