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Comment 121 for 2030 Target Scoping Plan Discussion Draft (sp2030disc-dec16-ws) - 1st Workshop.
First Name: Todd
Last Name: Shuman
Email Address: tshublu@yahoo.com
Affiliation: WUMU - Wasteful Unreasonable Methane Upr
Subject: 2030 Target Scoping Plan Discussion Draft
Comment:
To CA ARB As a supplement to my previously submitted comments, I also wish to submit for the record this article by Darien Shanske concerning state-level Border Tax Adjustments for prospective carbon taxes. The legal theory propounded and explored by Shanske addresses direct carbon tax mechanisms at the state level that would alleviate, minimize, and perhaps eliminate altogether, GHG "leakage" concerns. This material should be considered in conjunction with the previously submitted material in Springmann et al (2016), as CA ARB develops a Cap and Tax alternative to Cap and Trade. Again, such a Cap and Tax alternative should apply to the Agricultural economic sector and should address frequently-voiced concerns about GHG "leakage" that might occur if high-GHG-polluting industries (and the direct consumers of theses industries' commodities) are required in the future to "internalize" the social and environmental costs of commodity production that are currently being "externalized" to the broader society and environment. I would argue that Shanske provides the legal map for instituting, implementing, enforcing, and collecting state-level carbon taxes in a manner that will minimize GHG "leakage" in the future. Sincerely, Todd Shuman, Camarillo
Attachment: www.arb.ca.gov/lists/com-attach/124-sp2030disc-dec16-ws-AHNQPlQ0BThRJAFq.pdf
Original File Name: Shanske BTA Carbon Tax.pdf
Date and Time Comment Was Submitted: 2016-12-16 16:03:26
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