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I am writing to clarify what a cost-benefit analysis of the
proposed regulations should account for. There seems to be a
misunderstanding in the Draft Scoping Plan about what constitutes
a cost and a benefit.

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From the DRAFT SCOPING PLAN: 

“ARB is also evaluating the potentially beneficial impacts of new
job creation in the emerging “greentech” industry…” p. 53-54

“California’s climate change program will generate investments in
climate change emission reductions, yielding potentially vast
economic benefits to California…In addition, the process of
developing and deploying green technologies creates new businesses
and new jobs. The savings from both reduced energy spending and the
income from new jobs is channeled back into the state’s economy.”
p. 54-55


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These statements indicate that ARB is going to count jobs and
industry created to implement the new regulations as a benefit.
However, in an accurate cost-benefit analysis these jobs and
investment are counted as a COST, not a BENEFIT of the proposed
regulations.  The people of California deserve an honest
accounting of the costs and benefits of the proposed regulations.

Sincerely,

Peter Wilson