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Comment 22 for Low Carbon Fuel Standard - General (lcfs-general-ws) - 1st Workshop.


First Name: Stephen
Last Name: Rush
Email Address: SLRush@ForFuelFreedom.com
Affiliation: For Fuel Freedom, Inc.

Subject: Cap & Trade Planning & Regulation Recommendations
Comment:
Recent reports by certain fiscal oversight organizations and
corporations (such as PGE) speak of Cap & Trade as a bad idea that
will only overburden the electric power consumer.  Not exactly
true.  The net effect of Carbon tax / Cap & Trade - if the program
is written well and well thought out - will be a good investment on
the part of the taxpayer/consumer without being overly burdened
through energy cost savings in time and will help energy companies
not merely manage their emissions but earn profits while being
environmentally conscious.
 
As CEO of a bio-fuels and technology company, and as an informed
leader in the industry, there are many companies large and small
that are looking forward to incentives and putting pressure on
power plants and industrial centers to clean up their air.  Despite
the cost to the taxpayer and consumer initially, if this is done
right will generate jobs, help stabilize the economy, and
eventually reduce costs to the consumer.  However, many technology
companies that can perform this function are small businesses that
have scaled back their workforce recently, leaving the core of
their business workload to the executives and utilizing personal
credit to keep their business alive.  So whatever the plan that is
put into place, it must account for the current economics, and my
first recommendation is to waiver permitting and fees up front, but
to be recaptured in taxes.
 
With this in mind, the bill would work to create energy jobs if
carbon trade is specifically written as an investment into
carbon-reducing development and expansion by companies that have
anything to do with renewable fuels, sequestration, solidifying, or
any such process.  There are economic benefits of scrubbing CO2,
since it can be used as oil extraction, deep freeze, cleaning
solvent, and making algae for use as bio-diesel or high-grade jet
fuel.  Each company has varying technology and profitability from
the next, but the important thing is making that CO2 available.  My
second recommendation for these carbon development monies is to
legislate that commodity traders must provide carbon trading
brokering services when necessary, and that the cost of exchange is
reasonable and is absorbed by the producer of carbon or a maximum
of 3% gross profit of the user.  But that is not the only
consideration.
 
The bill would work to create energy jobs if there is a carbon tax
for significant expulsion of pollutants over a certain amount, or
non-compliance, and preferably that tax will increment quarterly. 
Without a financial burden to motivate companies to look around the
various markets for profitable technologies so that they can make
up the difference for the cost to capture / sequester and utilize
that carbon, then that CO2 would be hard to force them into looking
at other forms of energy.  My third recommendation then is to
legislate that there be a carbon tax of around $137 per ton of CO2
or $1,300 per MW if none of these technologies are used.  If carbon
generation sources do wish to utilize a carbon capture technology,
then might I suggest the carbon “waiver” paid directly to the
technology company in the amount of $77 per ton of CO2 or $730 per
MW, and a minimum of 33% of the total must go toward companies with
technology in some phase of development but not fully
commercialized.  (To give an idea, the cost to store CO2 is
approximately $165 per ton, yet the profit for our algae system is
between $10 to $30 depending on transportation costs once
constructed but our capital costs are roughly $595 per MW.) 
Because technology companies may not allocate 100% to a fully
functioning facility, they must reserve or grant 15% to a
participating company to encourage such future building projects
through a facilitated pool.
 
The bill would work if there was a review process to ensure
inclusion of every American company that wanted to participate. 
So, my next recommendation is make exemptions for participants to
deviate from previously established program requirement laws, in
addition to the above recommendation.  For example, the development
and technology companies must qualify by hiring mostly in
California for this project, and if there are any program bids they
must be shared by percentage of the dollar amount of the next
lowest bid so all that can stimulate the economy will participate,
no matter their stage of development and without grant deadline.

America needs to get working again and small business need the
free flow of money that comes from a plan such as this.  Please
give this your most undivided attention.  Thank you.

Stephen L. Rush, CEO
For Fuel Freedom, Inc.
Inland Empire, CA  92399
(909) 213-2750 (direct)
SLRush@ForFuelFreedom.com

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Date and Time Comment Was Submitted: 2009-10-12 14:29:53



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