Comment Log Display

Please auction off all emission credits. Program revenues should go
toward GHG reduction programs, such as clean technologies, green
jobs, and aid for low-income consumers and small businesses to
reduce their energy bills.  And please work to reduce the role of
offsets in the Plan. Providing too many offsets encourages
continuing emissions in low-income neighborhoods and in defenseless
habitats, and weakens the demand for clean energy technology and
jobs in California.





- Big polluters should pay for all their emissions: 100% auction
of emissions permits, no free giveaways.

- Consider cap-and-trade just a minor tool among market
mechanisms. Other tools should be brought forward more robustly,
including feed-in tariffs and carbon fees in the Plan's near-term
action agenda.

- Make sure the 33-percent renewable electricity standard by 2020
is given the force of law, either through legislation or regulatory
action.

- Promote and enable Community Choice Electricity Aggregation
(CCA) and its potentially powerful GHG reduction potential for
cities and counties.

- Give more specificity and amplitude to the goal of electrifying
transportation, especially greatly expanding ZEV numbers (plug-ins
and electric cars) beyond CARB's currently too low projected
levels.

- Greatly strengthen the too-modest land use and agricultural
sections of Plan. The Plan greatly underestimates the significance
of methane emissions, by using the 100-year global warming
potential. Over a shorter time horizon, methane accounts for 17% to
perhaps well over 30% of the state's GHGs, rather than the 5.7% in
the 2004 inventory.

- Further increase requirements for zero waste and recycling, as
well as Extended Producer Responsibility.

- Ensure that actions to reduce greenhouse gases also help,
whenever possible, to clean up California's unhealthy air.

- Limiting offsets will strengthen the demand for clean energy
innovation, which in turn provides more good jobs for
Californians.

- Any offsets allowed should at most represent only a small
portion of a polluter's required emission reductions. They should
have stringent protocols ensuring that the reductions are
quantifiable, new, permanent, subject to independent third-party
verification, enforceable by CARB, and only located in California.

- Offsets from sinks, such as planting trees or avoiding tree
cut-downs, should not be allowed, since they are too difficult to
measure and often under-perform.