Comment Log Display

December 14, 2010

Clerk of the Board
California Air Resources Board
1001 I Street
Sacramento, CA 95812

Subject:	Support for Adoption of a Proposed California Cap on
Greenhouse Gas				Emissions and Market-Based Compliance Mechanisms
Regulation, Including
Compliance Offset Protocols

The California Energy Efficiency Industry Council supports the
adoption of the proposed cap and trade regulations for the purpose
of putting a price on carbon. For decades, California has been at
the forefront of creating effective environmental and clean energy
policies. As a result, these policies are stimulating innovation
and efficiency, positioning the state as a leader in this thriving
global marketplace, and creating new businesses and jobs.  We see
the proposed regulation as another positive step in California’s
leadership, by demonstrating how to develop an energy
infrastructure in a carbon-constrained world.  We believe the
regulation will also support a stable energy and business
environment that will result in our member companies being able to
grow and employ more Californians.

We do have a few suggestions though:

1.	The Air Resources Board and/or the CPUC must establish strong
oversight to ensure that funds generated as a result of the
regulation are only spent on any appropriate consumer rate relief
and GHG-reducing measures such as energy efficiency and the use of
renewables. Given the free allowance allocation provisions, it is
of particular concern that there is investment in mitigation versus
windfalls for any participants. 

2.	All participants must realize that a cap and trade system does
not replace our State’s other greenhouse gas mitigation policies
and thus we need to stay the course and even expand implementation
activities related to energy efficiency and other clean energy
policy initiatives. This particularly includes the public benefits
charge funding for energy efficiency programs.

The Efficiency Council is an association representing businesses
that provide energy efficiency services and products in California
(www.efficiencycouncil.org). The energy efficiency industry
continues to expand in California, creating jobs and saving energy
and dollars for residents and businesses feeling the economic pinch
throughout the state.  The Efficiency Council membership includes
energy service companies, engineering and architecture firms,
contractors,implementation and evaluation experts, financing
experts, and manufacturers of California Air Resources Board energy
efficiency products and equipment. The member companies of the
Efficiency Council have over 110 different offices in cities from
Eureka to San Diego to help California residents and businesses
save energy in every corner of the state.  Our member companies
will be hiring more individuals in California in the years to come,
assuming a continued policy of clean energy and environmental
stewardship.    

Thank you for your time and consideration.


Sincerely, 

Steven R. Schiller, P.E.
Board Chair