Comment Log Display

Greetings ARB Board and staff

The California cap and trade system is the best sector-wide cap and
trade program in the world and it must succeed.  I have always been
concerned for the future of the ARB cap and trade system as well as
some of its more critical components like the offset program, but
this last webcast makes me afraid that it is more at risk than
ever.  This is unfortunate timing since although cap and trade is
sited by many experts as the best way to fight climate change, it
is still being threatened as a concept.  It has been tried as a way
to fight GHG emissions a number of times around the world with
little success.  The European cap and trade system, for example,
was initially successful at limiting GHG emissions, but without a
shrinking cap, the system has failed to reduce GHG emissions
further.  The Regional Greenhouse Gas Initiative (RGGI) has also
been successful, but the program is specific to power plant
emissions only.  There are many voluntary carbon markets across
numerous countries, but they have achieved very little.  By
contrast California Cap and Trade is an aggressive program that
does not stagnate with its own successes.  It provides incentives
to capture and destroy fugitive emissions outside the direct
purview of cap and trade.  As old goals are achieved new goals are
set by the falling cap.  The incremental process, and highly
scrutinized market mechanisms, gives industry the time and
incentives to innovate and adjust without giving time to become
complacent.  California Cap and trade must survive not just for
itself but for the world.

The world still regards cap and trade as an experiment.  If
California cancels its cap and trade program, cap and trade will be
dismissed by critics as a valiant, but failed, effort.  And it will
set an international precedence that cap and trade does not work as
a sector wide solution to climate change.  Whether or not
California feels responsible for setting an example to the world,
the world is watching.  And like it or not, California's decision
on this matter will have global consequences.  The consequences
will naturally affect Americans eventually.  Even if cap and trade
isn’t absolutely perfect it is effective and implementable. 
Developing a new program would take years, and then several more
years working out the kinks.  Cap and trade has been in place for
over 4 years and that time has been used to identify weaknesses,
and implement improvements.  It is therefor my strong feelings that
cap and trade be upheld, not curtailed or reduced.  

In both the latest cap and trade workshop, and the cap and trade
environmental impact assessment report, there was startlingly
little discussion about climate change.  The main topic of the
impact assessment was co-benefits of cap and trade, or more
specifically the prevalence of toxic air pollutants and particulate
matter (criteria air pollutants) in disadvantaged communities.  The
only significance of climate change in the impact assessment, was
in comparing the relationship GHGs have with criteria pollutants. 
At no point during the impact assessment did the authors mention
what the impact of climate change would be on disadvantaged
communities.  Climate change seems to be a low priority to the
composers of this assessment.  In fact the words “climate change”
are only used 3 times in the impact assessment none of which were
in the body of the report.  Since AB 32 or The Global Warming
Solutions Act was passes with the specific purpose of slowing
global warming to a natural pattern; It would seem the assessment
writers are either not fully aware of the specific intention of AB
32 or they are recommending changing the purpose of AB 32 to focus
primarily on criteria pollutants.  

Experience in renewable energy legislation has demonstrated that
the more agendas a law or regulation attempted to fulfill, the less
effective it is at fulfilling any of them.  For cap and trade to
work best it must have a single, clear and concise purpose.  While
opportunities for co-benefits should not be ignored they must never
supplant the main purpose of cap and trade.  Currently that purpose
is fighting “Global Warming”, increasingly refereed to as “Climate
Change”.  Detracting from that purpose to serve some other agenda,
would be to betray the spirit of AB 32 as well as the people who
fought to get it passed.  
	
It is disturbing but not shocking to hear that there is a
disproportionate volume of disadvantaged communities living near
facilities that emit high volumes of criteria pollutants.  Since
these pollutants are highly controlled I believe there are better
ways to track there volumes then to track GHG emissions and assume
the criteria pollutants follow along.  In fact on page 13 of the
assessment the authors state that they obtained the criteria
pollutant data from the monitoring and tracking mechanisms already
in place to control criteria pollutants.  This tracking system is
known as CEIDARS.  CEIDARS exists because of an EPA mandate to
reduce criteria pollutants under the Clean Air Act, however if
further reductions in criteria pollutants are necessary then
aggressive action should be taken.  A cap and trade program
specifically designed for GHG’s is an inappropriate mechanism for
this.  Criteria pollutants must be controlled and eliminated by
their own program, unencumbered by tertiary concerns.  Such
programs already exist, and it is in these programs that are the
best tools to further eliminate criteria pollutants can be found. 

	
Offsets are constantly blamed for creating more emissions, or
allowing emissions that otherwise would not have occurred.  The
creation of an offset requires immense amounts of data monitoring
and redundant third party scrutiny which is itself scrutinized. 
This means that multiple third parties and then CARB itself has
proven that all offsets are real and additional.  So why then are
offsets accused of doing the exact opposite? 
	
The environmental assessment report advocates reducing or
preferably eliminating offsets, and while having read the report
several times it is still unsure for what reason.  The 2 research
findings presented are that most offsets are purchased by the
highest emitters, and that the total tCO2e of GHG reductions
achieved by offsets alone were 4 times greater then the target
reductions for 2013.  To the first point, it should come as no
surprise that those with the highest emissions would be the most
interested in buying offsets.  Since allowances could have been
purchased in place of these offsets, it is unclear how this fact
correlates to increased emissions.  The exact argument is never
made in the assessment.  The second damning fact is even more
puzzling since it seems to suggest that offsets are, at least in
this early stage of the program, achieving more emission reductions
then the falling cap (12 million tCO2e of reductions from offsets
in 2013).  Why would someone concerned with climate change advocate
eliminating 4/5th of the GHG reductions currently being achieved? 
If the concern is other then GHG reductions and climate change,
then those concerns should be considered under the appropriate
regulatory framework(not AB 32).   
	
The truth about offsets is that every offset purchased is 1tCO2e of
GHG’s removed from the atmosphere that would not have been removed
if an allowance was purchased instead.  The truth is offsets are
the most powerful tool cap and trade has for fighting short lived
climate pollutants.  If anything offsets should be increased.  
	
Climate change is an urgent and global problem that will likely
effect underprivileged communities disproportionately.  California
being a coastal state is at an even greater risk then most to the
adverse consequences of climate change.  If there are problems with
cap and trade or any of its components they should be improved, not
eliminated or curtailed.  It is paramount that the world see cap
and trade succeed, a success that offsets are an integral part of. 
To succseed cap and trade must not only survive, but thrive.  And
to do so it must remain focused on GHG reductions and retain a
strong offset program.

Evan Vessels
Vessels Coal Gas Inc.