Comment Log Display

The Plan greatly underestimates the impacts of increasing
urbanization and deforestation in California. 

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 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 easily reachable goal
of electrifying transportation, especially greatly expanding ZEV
numbers (plug-ins and electric cars) beyond CARB's currently far
too low projected levels.

- Greatly strengthen the too-modest land use and agricultural
sections of Plan. The Plan greatly underestimates the impacts of
increasing urbanization and deforestation in California, and 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 increases in
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 and improvments in efficency, 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 from
efficency gains and actual reductions, quantifiable, new,
permanent, subject to independent third-party verification,
enforceable by CARB, and only located in California .

- Although preservation of california's remaining forests and
chapparal wildlands must be a priority, 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.