Comment Log Display

To the CA ARB,

I concur with other comments submitted today (by CRPE and its
allies) that the CA ARB has inadequately analyzed and considered a
carbon tax in this CEQA proceeding/CEQA process/CEQA document. 

I too insist that the ARB Board engage in a good faith and reasoned
analysis of the benefits that a carbon tax offers. 

Moreover, I insist that ARB go further and engage in a good faith
and reasoned analysis of a broader Greenhouse Gas (GHG) Emissions
tax that would apply to all the GHG emissions that flow from the
Agriculture economic sector -- and include GHGs that are not
carbon-based (such as nitrous oxide, N20),as well as GHGs that are
both long-lived (e.g. CO2 and N20) and short-lived (e.g., methane).


The model for this particular unified GHG "Ag" taxation approach
was recently published in "Mitigation potential and global health
impacts from emissions pricing of food commodities", Marco
Springmann, Daniel Mason-D’Croz, Sherman Robinson, KeithWiebe, H.
Charles J. Godfray, Mike Rayner and Peter Scarborough, Nature
Climate Change, 7 NOVEMBER 2016 | DOI: 10.1038/NCLIMATE3155.

I am attaching this recently published study to facilitate ARB
development of a serious GHG-based direct taxation approach as part
of an alternative to Cap and Trade. As such, I insist that ARB
review this study and produce a good faith and reasoned analysis of
a "Cap and Tax" alternative to "Cap and Trade" that is informed by
the Springmann et al (2016) study attached. 

I want to emphasize for the record that ARB should include within
this Cap and Tax alternative all the GHG emissions that are
produced by the Agriculture economic sector in California,
especially with reference to the dairy and livestock industries.

(Note: the attached paper has a link to the supplementary material
for this paper that ARB will want to analyze as well.) 

Through this referencing above, I request that the supplementary
material for the Springmann et al. [2016] paper be also considered
as part of the administrative record of this proceeding.

Sincerely,

Todd Shuman, Camarillo