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Dear CARB and stakeholders,
 
Thank you for the opportunity to comment on the CARB 2030 Target
Scoping Plan.
 
For context, Citizens’ Climate Lobby is a non-partisan national and
international organization of more than 45,000 citizen lobbyist
volunteers dedicated to building the political will in Congress for
a livable planet. In California, CCL has over 9,000 members who are
active in 39 chapters across the entire state.
 
Last December, over 50 members of CCL from around the world
participated in the civic engagement sessions at the UN COP21 talks
in Paris. We carried with us our advocacy for guiding principles
for carbon pricing that underlie all of CCL’s policy development
and lobbying efforts. We promote carbon pricing that is:
 
Effective: reduces economy-wide absolute greenhouse gas emissions
while supporting domestic economic growth across all sectors.

Efficient: minimizes the cost of implementation while maximizing
environmental, economic, and social co-benefits.

Equitable: avoids disproportionate burdens while protecting
vulnerable populations from unjust or negative economic or
environmental impacts.
 
These principles reflect those that underpin the international
Carbon Pricing Leadership Coalition, of which California is an
official member.
 
CCL’s principal focus is on lobbying the US Congress to pass a
fully-rebated fee on carbon. However, in recognition of the huge
role that California plays worldwide in innovative and effective
climate action, over the past year we have also reached out to our
state legislators in California, as well as selected environmental
and environmental justice organizations in the state. Our purpose
has been to educate them about the CCL proposal and how a national
carbon fee and dividend could co-exist with the state’s current
Cap-and-Trade program. In August 2016, the State Assembly and
Senate passed Assembly Joint Resolution 43, calling on the US
Congress to enact a national carbon-fee-and-dividend program.
 
In the spirit of strengthening California’s effective programs to
reduce GHG emissions statewide while providing a model for other
states and nations, we offer these comments on the Draft Scoping
Plan.
 
Overall, we are happy to see that CARB has committed to analyzing
carbon pricing mechanisms in addition to the current Cap-and-Trade
program. However, we believe that the Scoping Plan stills lacks
critical information necessary for your board, as well as other
interested stakeholders, to be able to accurately and
comprehensively assess the carbon pricing scenarios contained in
the plan, and to evaluate their efficacy in reaching the new 2030
emissions reductions targets.
 
Specifically, we respectfully request that CARB undertake a much
more comprehensive analysis and comparison of a carbon tax—with a
variety of rebate options and/or reinvestment options—along with
reforms to the existing Cap-and-Trade Program. We all need to
understand how effective each of these scenarios can be in
achieving California’s aggressive 2030 GHG emissions targets.

In the attached, we include some information we hope you will
consider as you revise the Scoping Plan.

Thank you again for this opportunity to comment on your work.
Citizens’ Climate Lobby is happy to provide any resources or
information we can to support California in developing its climate
plans. Please don’t hesitate to contact us.

Thank you for doing this critical work for the health and
well-being of all Californians and the world. 

Sincerely,

Tasha Reddy, PhD
CCL California State Coordinator
tasha.reddy@citizensclimate.org