Comment Log Display

The Coalition for Clean Air (CCA) favors Alternative 2 (Carbon
Tax), combined with robust regulatory measures, among the policy
scenarios outlined by the Air Resources Board (ARB) to comply with
Senate Bill 32 (Pavley, 2016) requiring a 40% reduction of
greenhouse gas (GHG) emissions below 1990 levels by 2030. We
support a carbon tax and request ARB staff to explore the
possibility of including a cap on GHG emissions along with the tax
in order to ensure emissions decline from 2020 to 2030 and do so in
a predictable manner. In addition, we strongly urge ARB to extend
the carbon tax to cover emissions of criteria air pollutants and
toxic air contaminants as well. All tax revenues should be invested
in programs that reduce those emissions, especially to projects
located within and benefitting individuals living in disadvantaged
communities (DACs). CCA favors an emissions tax, with proceeds
channeled into pollution-fighting programs, because of the
environmental protection and justice principles and goals embodied
in such a carbon pricing mechanism.
First, an emissions tax is based on the “polluter pays” principle
that requires the entities responsible for generating emissions to
pay for the cost of that pollution in order to mitigate or prevent
damage to environmental and human health. Second, investing
revenues from an emissions tax in pollution-reducing measures could
help deliver important co-benefits that support additional
environmental and public health goals, because the sources of GHG
emissions and air pollutants are usually one and the same.
Guaranteeing the use of emissions tax revenues for climate change
and air pollution mitigation would also maintain a vital source of
funding available for the Greenhouse Gas Reduction Fund (GGRF),
which is an established and sound framework for certifying
investments are balanced in a manner that complements and furthers
California’s environmental and sustainable development laws,
regulations, and goals (e.g., SB 1275 and 1204 as well as SB 375,
regarding low carbon transportation and reducing vehicle miles
traveled, respectively). The demand for incentive funding is
especially acute in the South Coast and San Joaquin Valley regions,
where air quality is the worst in the nation, thus underscoring the
basis for an emissions tax that addresses both GHG emissions and
air pollutants. Furthermore, the State’s carbon pricing system
should continue to be used in ways that promote environmental
equity and climate justice. Specifically, this means continuing to
adhere to legal requirements (SB 535, 2012, and AB 1550, 2016) that
ensure a significant share of revenues from the State’s climate
program is invested in and benefits people living in the
communities where environmental pollution and contamination has
been concentrated – communities in which residents are often
predominantly and disproportionately low-income and/or people of
color.
Coalition for Clean Air agrees that the category of “known
commitments” will be responsible for delivering a majority of the
reductions in GHG emissions needed to meet the 2030 target. CCA
supports these measures that have proven effective at lowering
levels of carbon pollution, such as renewable electricity,
clean-car and building energy efficiency standards. We also agree
with the proposal in all three post-2020 policy scenarios to
strengthen the Low Carbon Fuel Standard by lowering the carbon
intensity of transportation fuels by at least 18% by 2030. Rapidly
increasing the target for zero-emission vehicles (ZEVs), as
proposed in all three policy scenarios, should also be pursued.
California’s transportation sector needs to move rapidly toward
zero- and near-zero emission technologies to achieve federal
health-protective air quality standards and California’s climate
change mandates, as noted in the 2012 “Vision for Clean Air.”
Accordingly, CCA recommends strengthening other existing measures
in the transportation sector, which is expected to remain the
largest contributor to carbon and air pollution in California. The
Sustainable Freight Strategy measure should be strengthened, for
instance, and CCA has and continues to recommend higher
zero-emission technology and freight system efficiency targets than
those outlined in the California Sustainable Freight Action Plan.
Reducing the impact of California’s freight industry is
particularly important because goods movement is projected to grow
in the coming years and disadvantaged communities located near
freight hubs and facilities bear a disproportionate share of the
negative effects of freight transport. In addition, ARB should
consider enhancing implementation of the Sustainable Communities &
Climate Protection Act of 2008 (SB 375, Steinberg) by strengthening
the emission reduction targets Metropolitan Planning Organizations
(MPOs) must meet and bolstering the review and enforcement of MPOs’
Sustainable Communities Strategies. Examples of specific
transportation planning measures that CCA supports include:
increasing transit ridership and reducing GHG emissions by
targeting funds to operate increased levels of transit service and
implementing fare reduction strategies that incentive greater
transit utilization.    
Clear and firm regulatory standards have been the most effective
tool for reducing emissions and driving technological innovation,
the two most important results of the Global Warming Solutions Act
of 2006 (AB 32). To that end, Coalition for Clean Air strongly
supports the Refinery Measure concept, and recommends setting the
target at a minimum of a twenty percent reduction in GHG emissions
by 2030. We support this measure because it would begin addressing
carbon pollution from the largest stationary source of GHG
emissions in California within the leading sector of those same
emissions (i.e., transportation). This measure, by helping lower
emissions of criteria air pollutants and toxic air contaminants,
would also offer meaningful environmental and public health
co-benefits to the communities located adjacent to or near
refineries in California. Likewise, ARB should also consider
proceeding with measures to reduce emissions from oil and gas
extraction, which should help rural areas of California in
particular to experience meaningful improvements in air quality and
public health, while helping the State meet its 2030 GHG target.
CCA also urges ARB to begin developing measures to address other
industrial sources of emissions – namely, cement plants and general
fuel use by industry – because emissions from those segments are
growing and are likely to continue to do so with greater
construction and commercial activity in California.
CCA would also like to comment on the Draft Scoping Plan scenario.
If a post-2020 cap-and-trade program is enacted, then CCA urges ARB
to adopt changes that would decrease emissions at the source as
called for in AB 197 (E. Garcia, 2016). These changes include:
limiting the use of offsets to meet the emissions cap; auctioning
off nearly all emission allowances; and decreasing allocations to
covered facilities that report increased onsite criteria or toxics
emissions. Expert economists who advised ARB on establishing the
cap-and-trade program now in place had recommended the auctioning
of virtually all allowances. Moreover, free allocations only reward
stalling, delay, and obstruction of necessary cleanup at major
sources of air pollution.