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Dear Ms. Nichols and Board Members:

The Environmental Defense Center (EDC) is pleased to provide input
on the use of Cap-and-Trade auction proceeds to reduce greenhouse
gases (GHG) contributing to climate change. We support the request
of the Santa Barbara County Air Pollution Control District
(SBCAPCD) and Channel Islands National Marine Sanctuary (CINMS) to
use some of the funds to develop an incentive program that will
reduce the speeds of large marine ships traveling along the
California coast. 

An incentive based program using Cap-and-Trade funds to reward
large marine ships for reducing ship speeds from 18-22 knots/hour
(current speed) to 12 knots/hour along the California coast would
reduce carbon emissions and fulfill the goals of Assembly Bill 32
(AB 32).  Specifically, incentivizing vessels greater than 300
gross registered tons to travel at speeds 12 knots/hour or slower
would reduce GHG emission, protect whales from collisions with
vessel and noise pollution, and provide other benefits associated
with reduced speed.   Benefits from an incentive based program are
bulleted and details for each benefit are provided in the attached
pdf.  

1.	Significantly Reducing GHG Emissions from Ships
2.	Providing Additional Air Quality Public Health Benefits 
3.	Supporting the State’s Economy and Efforts to Develop a
Clean-Energy Economy  
4.	Reducing the Lethality and Severity of Whale Strikes and
Acoustic Noise Impacts
5.	Building on the Successful Existing LA Long Beach Green Ports
Program 
6.	Reducing Fuel Cost for the Industry 
7.	Reductions are Measurable and Verifiable 

The Cap-and-Trade auction fund provides a unique opportunity to
develop an incentive based program.  It is important to recognize
that this is a rare instance in which the Air Resources Board can
address multiple environmental concerns and fulfill multiple
objectives in AB 32 through a single mechanism

Thank you for your consideration of these comments.  Please do not
hesitate to contact me or Linda Krop, EDC Chief Counsel; at (805)
963-1622 should you have further questions or concerns. 
 
Sincerely, 

Kristi Birney 
Marine Conservation Analyst 
Environmental Defense Center 

Original File Name: Final EDC letter re CARB cap and trade 6-22.12.pdf

Date and Time Comment Was Submitted: 2012-06-22 12:44:58