Comment Log Display

Thank you to the State of California and the Air Resources Board
for leading the way to reduce greenhouse gas emissions, help
stabilize carbon dioxide concentrations in our atmosphere, and,
hopefully, avert some of the worst impacts of global warming. I am
submitting comments simply as a concerned citizen. 

First, the board should research, and the state should consider,
"cap and dividend" as an alternative to "cap and trade" market
mechanisms to reduce emissions over time. An increasing body of
evidence points to this as a better, more fair and stable
alternative.

Second, rights to pollute or "allowances" should be auctioned, and
not given away for free. No polluter should be grandfathered in.
Just because a particular industry or utility has been polluting
the atmosphere in the past, they should not be given the right to
consider doing so for free. I believe that setting up a blind
"all-in" auction is also economically most efficient.

Third, offsets should not be considered as part of the plan. I
understand the lure of the idea (why not  pay for a re-forestation
project in Borneo instead of making actual emissions reductions at
power plants in California, especially when they are cheaper?), but
offsets will delay the reductions at home (where Californians will
enjoy substantial co-benefits such as reduced sulfur dioxide and
nitrogen oxide pollution), and delay the technical innovation that
California industries and scientists are uniquely capable of
creating.

Fourth, the market in emissions allowances should be limited to
polluters themselves. We cannot seriously consider allowing big
banks and hedge funds to turn carbon into the next toxic asset. I
have serious concerns when I read about the amount of lobbying
being done by financial institutions. The state must guard against
collusion, speculation, and the pursuit of short-term financial
gain that will undermine the environmental goals of the program.

Thank you.