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Comment 57 for Design Comments for the GHG Scoping Plan (sp-design-ws) - 1st Workshop.
First Name: Garrett
Last Name: Fitzgerald
Email Address: gfitzgerald@oaklandnet.com
Affiliation: City of Oakland
Subject: Comments on Program Design
Comment:
Below are comments from the City of Oakland specific to Proram Design related to the Draft Scoping Plan. These comments were also included in the City of Oakland's letter submitted to the General Comments section of this website. 1. Economic Analysis on Low-Income Communities Needed The Plan references an economic analysis being conducted of potential impacts on low-income communities due for release in Summer 2008. The City of Oakland are very interested in this analysis and the potential impacts of the Plan on low-income residents of our community. In particular, we are interested in evaluations of the potential cost impacts that may be passed to residents/consumers through electricity and fuel surcharges, along with any programmatic fees that might be levied through other avenues. We have significant concerns that low-income residents may be disproportionately affected by these costs due to relatively low ability to pay, and urge that specific actions be taken to help offset these disproportionate effects. 2. Revenues Should be Invested via Local Governments to Cost-Effectively Reduce Additional GHGs, Increase Resilience to Climate Change, and Green California’s Economy Page 45 We strongly support the suggestion that a portion of program revenues should be invested in the form of “funding or other incentives to local governments for well-designed land-use planning and infrastructure projects [that] can do much to discourage long commutes and encourage walking, bicycling and use of transit.” Local governments, working independently and in collaboration with regional partners, have significant leverage in fostering vehicle trip reductions, a critical component to reducing transportation-related GHG emissions. Reducing vehicle miles traveled throughout the state will be critical not only to achieving the AB 32 goals but also the Governor’s stated goals of reducing GHG emissions by 80% by 2050. In addition, a portion of revenues should be targeted toward making specific transit and other infrastructure improvements in low-income communities, and potentially toward augmenting traditional low-income weatherization and bill assistance-style programs to help offset the disproportionate effects of program-related costs on low-income communities. A portion of revenues should also be invested in helping local governments to develop climate adaptation/resilience plans to help local communities best increase resilience to the ongoing, developing effects of climate change that are already happening. Finally, a portion of funds should be invested in workforce training to prepare workers for green jobs. These funds should be concentrated in areas where a significant number of workers can be engaged. 3. Do Not Rely Exclusively on Cap and Trade A system that relies exclusively on Cap and Trade could postpone investment in next generation technology. Coupling Cap and Trade with fees levied upon polluters to insist on minimum performance will allow more regulatory oversight and establish a floor price for carbon in the state. Results can be more comprehensive across technologies and challenges as regulators require progress on specific technologies to develop lower polluting alternatives on a specific time schedule. ARB should also consider imposing disincentives on ‘leakage’ (see Section 2B.1) to areas outside the WCI territory.
Attachment:
Original File Name:
Date and Time Comment Was Submitted: 2008-08-01 10:41:38
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