Comment Log Display

August 1, 2008

Mr. Robert DuVall
California Air Resource Board
1001 “I” Street
P.O. Box 2815
Sacramento, CA 95812

	Re: Comments: Draft AB 32 Scoping Plan

Dear Mr. DuVall:

The members of the California Small Business Alliance appreciate
the opportunity to comment on the Climate Change Draft Scoping
Plan, pursuant to AB 32, the California Global Warming Solutions
Act of 2006.

The businesses in California, particularly those belonging to the
Alliance, have struggled for decades to reduce the overall
emissions from the many different processes they use in the
conduct of their operations. By every acceptable method of
measuring the effects of pollution, the quality of the air in
California – especially the South Coast Air Basin – is remarkably
improved owing, in large measure, to the significant and
unrelenting efforts and investments by stationary sources.
Businesses in the South Coast have applied pollution control
equipment and methods that go much higher on the marginal cost
curve than those in other parts of the United States.   Because
California environmental regulators often face political and legal
difficulties in reaching the sources of about 90% of air pollution,
i.e., from boats, trains, airplanes and motor vehicles, the burden
of squeezing out extra reductions for each successive State
Implementation Plan has continually fallen to stationary sources.

Alliance members understand that there is still more to do to
improve our environment and public health. A small business owner,
more than anyone else, knows the value of being energy efficient.
And both employers and employees have suffered from sticker shock
this year when refueling company-owned or private vehicles. 

But, while we may embrace the concept of the Plan, we are far less
supportive of the way in which it is structured. If fact, we
believe that the suggested command and control measures place an
unreasonable burden on stationary sources to meet the 2020
baseline objectives. 

The matter of providing necessary protocols that will enable
stationary sources (businesses) to access adequate streams of
affordable emissions reductions credits (ERCs) should be of
primary concern to all stakeholders. As written, the Plan imposes
severe restrictions on offsets. We believe that all verified
offsets should be eligible for compliance use. On balance, we
believe that mandatory facility audits and controls are not
appropriate. The market will create a sufficient incentive for
facilities to find and implement cost-effective reductions. The
time for imposing substantial new reduction responsibilities is
not the time to further restrict the means of obtaining such
reductions. Further, given the nature of greenhouse gases, and the
way that these affect the atmosphere, there is a strong case for
worldwide trading of CO2 reductions.  Certainly, it is folly to
restrict trades to single neighborhoods.

With respect to energy efficiency, we believe that stationary
sources should be able to get credit for such improvements or for
investments in renewable energy strategies. 

Simply stated, we believe that layering command and control on top
of any market program will increase costs by making greenhouse gas
(GHG) reductions unavailable for trading.

Finally, we believe that California should phase in its program
using carbon intensity benchmarks instead of imposing facility
caps, at least until there is a broad regional or national GHG
proposal, if that ever comes to pass.

The Alliance is a non-profit, non-partisan coalition of many of
California’s most recognized trade associations. Collectively,
these associations are committed to providing small business with
a unified voice on matters involving the environment, economy,
workplace issues, and legislation that have the potential to
influence the business operations of their members and the
economic health and welfare of the people they employ. Some 20,000
companies belong to our trade association members. Nearly all of
these small businesses are classified as “manufacturers.” Most of
them compete in the global marketplace and provide good jobs and
benefits for thousands of productive workers, many with
disabilities. Suffice it to say, the vast majority of these
employers and employees are also registered voters. 

As mentioned earlier, we thank you for the opportunity to comment
on this most important plan. Further, we want you to know that we
stand ready and willing to offer our collective experience and
expertise in helping you to resolve any aspect of the plan that
would impact our members. 

Sincerely, 


Ivan Tether,
President
California Small Business Alliance