Comment Log Display

August 29, 2008

Ms. Mary Nichols, Chair
California Air Resources Board
1001 I Street
Sacramento, CA 95812

SUBJECT:	AB 32 Scoping Plan – Comments 

Dear Chairwoman Nichols,

On behalf of the Valley Industry and Commerce Association (VICA),
we are writing to submit our comments on the recently released AB
32 Scoping Plan. We compliment you and the staff of the California
Air Resources Board (CARB) for the time and energy that you have
spent on the composition of this important document.

VICA has discussed the plan with our members at length and has
adopted a set of principles that we believe should be applied to
the AB 32 Scoping Plan. These principles and policies are vital
aspects of ensuring that the plan is both effective and equitable
to all those impacted by the implementation of AB 32.

Enclosed is VICA’s AB 32 Scoping Principles document. We request
that you and your staff review the principles and incorporate them
into the finalized plan. VICA looks forward to partnering with CARB
as the implementation process of AB 32 moves forward. 

Thank you for your time and consideration.

Sincerely,

Carolyn Casavan		                Brendan L. Huffman
Environment & Energy Committee		President & CEO
Co-Chair

(attached and below)



VICA AB 32 Scoping Principles:

Position:  The Valley Industry and Commerce Association (VICA)
supports the following principles and practices as they relate to
the AB 32 Scoping Plan (released on June 26, 2008):

1.	The market mechanisms and fee structures in the Plan should be
designed to return revenues to the sectors and regions from which
they originate.  The Plan should protect against the
redistribution of wealth and should focus revenues on reducing
emissions and emission reduction costs, encouraging technology
development and providing alternatives.

2.	The Plan should place more emphasis on public transportation
and rail transport as a means of reducing greenhouse gas emissions
from mobile sources, which account for nearly 40% of the emissions
in the State.

3.	Tax credits should be provided for investments in energy
efficiency and renewable energy.

4.	In a cap and trade system, VICA supports allocation of credits
instead of auction, especially during the first 10 years of the
program, to give producers time to implement changes.

5.	Emissions reduction programs should be phased in gradually in
an effort to allow producers to adjust to new mandates to avoid
shocks to any particular market.

6.	More incentive based measures should be included in the Plan to
induce not only compliance, but also encourage producers to go
beyond 2020 targets.

7.	The Plan should acknowledge and provide some form of credit for
early actions.

8.	The Plan as currently proposed focuses primarily on stationary
sources and business for achieving the targets. Emission reduction
requirements should be applied to all sectors in proportion to
their contribution to the State’s inventory to avoid overburdening
individual sectors.  

9.	The use of offsets for compliance should not be limited to 10%.
 Offsets provide cost-effective emissions reductions and encourage
innovation in all sectors.  All verified offsets should be allowed
to be used for compliance.


10.	The Air Resources Board should be the lead implementation
agency for AB 32.  The Plan should require that actions and
programs developed by local or regional agencies are consistent
with the State program and avoid duplication of effort.

11.	When calculating cost effectiveness of a project, only green
house gas emissions should be used and not co-benefits. Including
co-benefits in the cost-effectiveness calculations skews results
and may end up favoring technologies with low greenhouse gas
benefits.  

12.	Instead of imposing mandatory audits and controls, the plan
should allow the market to decide how best to develop and
implement the most productive and cost-effective means of reducing
greenhouse emissions.  

13.	Projects that comply with AB 32 guidelines should not be
required to do a separate CEQA review or be subject to additional
mitigation for greenhouse gases.

14.	Eliminate the water sector public goods charge.  This charge
unfairly burdens urban water users and attempts to duplicate
measures already being implemented by water providers.