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The purpose of this comment is to register my opposition to the
CARB cap and trade plan currently under consideration.  Our state
is already one of the least competitive places to do business, and
as an intellectual property attorney I see daily the struggles my
clients face dealing with extremely high energy costs,
uncompetitive taxes, and an extremely difficult regulatory
environment.  With energy costs already at least 50% higher than
those of other states, including neighboring states, it is
difficult to see how anyone can think that layering on billions of
dollars in additional cap and trade costs will help.  The best
middle class jobs are manufacturing jobs, and we are killing our
manufacturing sector with our toxic business environment.

I understand that CARB's cap and trade auction will be managed by
international financial firms like Deutsche Bank and Market North
America and will be open to Wall Street traders and speculators who
will profit at the expense of hard-working taxpaying Californians. 
What will prevent the kind of market manipulation that led to the
recent energy and mortgage crises?  This is just another example of
government intervening to help friends and hurt everyone else.  The
auction is a tax on California businesses that their competitors in
other states will not have to pay. This will hurt the economy, and
lead to even more businesses fleeing California for other states,
taking jobs and tax revenues with them.
 

This hidden energy tax is unnecessary because the carbon reductions
required under AB 32 can be achieved without a cap and trade
auction. The auction is just another way to raise money for CARB to
spend on programs and subsidies (like the federal government's
Solyndra disaster for example) with no accountability as to their
cost-effectiveness or environmental benefit.