Comment Log Display

Comments of Todd Shuman, Wasteful Unreasonable Methane Uprising,
April 7, 2017


A. Appendix E in the current CA ARB Scoping document does not model
a Cap and Tax approach. It just refers to the modeling for
Alternative 1 to provide insight into how a Cap and Tax approach
might function and impact emission reductions and overall state
economic activity. This failure to fully model a Cap and Tax
approach constitutes a CA ARB failure to comply with CEQA.


B. CA ARB fails to explore the conditions under which a Cap and Tax
system could minimize leakage and economic relocation. A
fully-compliant CEQA ARB analysis needs to explore and input a
variety of assumptions and scenarios and then model them to
generate a range of possible results based on the varying
assumptions and scenarios. CA ARB should also have explicitly
explored conditions in which Darien Shanske's "formulary
apportionment" approach (which I previously submitted to CA ARB and
which I again submit to CA ARB)is incorporated into the carbon tax
and cap and tax alternative modelling. Failure to do so constitutes
CEQA non-compliance.


C. CA ARB's comparative analyses between the recommended proposal
(mostly a supplemented Cap and Trade system) and the carbon tax
alternative remains biased against the carbon tax concept. Wara and
Cullenward have repeatedly critiqued CA ARB in previously submitted
comments concerning this matter, and the most recent CA ARB
document does not appear to address such critique, especially with
regard to the "quantity certainty" issue – which is fundamentally
related to the "unlimited allowance banking"* that would still be
allowed during the 2020-2030 period under the current preferred ARB
proposal. As a result, the CA ARB analysis currently remains
slanted and biased against both the carbon-tax-only alternative and
the cap-and-carbon-tax alternatives. Such bias constitutes CEQA
non-compliance.


D. The "social cost of carbon" values used in Appendix E are taken
from EPA. These EPA values are very low relative to a more
comprehensive social/environmental cost of carbon dioxide/ton
presented in Dr. Drew Shindell's "The Social Cost of Atmospheric
Release", 2015 ($46/ton versus $110/ton, CO2.) The use of such a
low social cost of carbon (in terms of CO2 tonnage) severely
distorts the ARB analysis and renders it in non-compliance with
CEQA. [See "The social cost of atmospheric release", Drew T.
Shindell, Climatic Change (2015) 130:313–326, DOI
10.1007/s10584-015-1343-0, page 319, Table 2, Median total;
declining rate.

E. Finally, CA ARB fails to reference and discuss a recent study
concerning leakage that is likely relevant to the different
alternatives. The study and its findings are discussed below. (See
http://legal-planet.org/2016/05/30/the-economic-impact-of-ab-32-on-california/.
Dan Farber[the Sho Sato Professor of Law at the UC Berkeley School
of Law and Co-Director of the Center for Law, Energy & the
Environment] wrote this observation about the May 30, 2016
Resources for the Future study: "[O]verall, the economic impact
seems small. That's also important because it means that carbon
leakage from production shifting is also probably small.")





Sincerely,

Todd Shuman, Camarillo, WUMU, http://wumu-wuru.my-free.website


[*Wara/Cullenward note that "unlimited allowance banking" in cap in
trade systems typically results in emissions reduction
"overcompliance" early on (when compliance costs are lower) and
emissions reduction "undercompliance" later on (when compliance
costs are higher, relative to the earlier phase of a typically
decadal compliance period.)]