Comment Log Display

After reviewing the Clean Power Plan Compliance Discussion Paper,
we offer the following comments:

While our organization has long been involved in ARB climate change
processes and generally supports ARB's efforts to reduce GHGs, we
have never been supporters of Cap and Trade. We continue to be
concerned about the abstruseness of the regulatory structure--no
one besides the lawyers involved really understands it--as well as
its potential to be gamed. We were strong advocates of a carbon tax
in our comments on the first Scoping Plan, and continue to see its
superiority, especially after its real-world success in British
Columbia.

We suggest that a carbon tax be adopted as the backstop mechanism
for the Clean Power Plan. It would not be triggered unless a
massive policy failure, such as widespread gaming, occurred or
there is a failure of nerve by either the Legislature or the Board.
A carbon tax in the backstop position would act as a strong
deterrent to gaming or backsliding, because of its unquestioned
effectiveness.

BTW, we found the following sentence impossible to understand: "For
California, U.S. EPA calculated a final statewide mass goal in the
2030-31 period of 96.8 million short tons of CO2 (e.g., 48.4
million short tons, approximately, in 2030)." It is entirely
non-obvious why half the mass goal is stated in parentheses. Please
either clarify or correct the text.

To further inform stakeholders, it would be useful to calculate the
actual emissions reduction percentage for CA EGUs, using the EPA
mass goals.

Thank you,

David Schonbrunn