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See attachment for full comment, excerpt below:

To: California Air Resources Board (ARB)

Regarding the ARB’s Plan for Investment of Cap-and-Trade Auction
Proceeds, the best use of revenues from an auction of permits under
the AB32 cap-and-trade program is to return auction proceeds to the
public through a dividend. Although rebates are already being
contemplated for the electricity sector, costs from the carbon
price will be passed down to consumers in the industrial and
transportation sectors as well.  Dividends accomplish the
additional goals of AB32 relating to equity, and maximizing
additional environmental, economic, and overall societal benefits,
and are therefore not legally risky.  ARB should work with the
Governor to ask State Legislators to amend bill AB1532 (Perez) to
include dividends as a potential category for the Air Pollution
Control Fund.

Multi-billion dollar infrastructure projects such as high-speed
rail are problematic investments because they could easily swallow
up all the revenues from cap and trade, yet still be unable to
contribute significantly to the state’s GHG reduction goals by
2020. A general problem with investments that seek to reduce
emissions under the cap is that they simply create space for more
emissions by "freeing up" emissions in other sectors under the cap.
 The ARB should include a discussion of this problem in the
Investment Plan.  

Despite the above concerns, it is reasonable to set aside 25% of
proceeds for investments, as long as 75% goes back to consumers as
climate dividends.  This follows the advice from the experts of the
Economic and Allocations Advisory Committee (EAAC).  If state
legislators make the dividends taxable, a portion would come back
to the State, free of the Sinclair restrictions. Dividends will
reimburse the public for their share of revenues from the Commons,
and avoid a public perception of climate change as just one more
budget item, floating in a sea of eroding social services. Taxable
dividends provide benefits for the State and the people of
California. 

Sincerely,

Mike Sandler

Original File Name: Comment to ARB Cap Trade 6-15-12.pdf

Date and Time Comment Was Submitted: 2012-06-15 08:45:25