| First Name | Jasmin |
|---|---|
| Last Name | Ansar |
| Email Address | jansar@ucsusa.org |
| Affiliation | Union of Concerned Scientists |
| Subject | Letter from Economists on the Proposed Cap-And-Trade Regulations |
| Comment | December 13, 2010 Chairman Nichols and Members of the Board California Air Resources Board 1001 “I” Street Sacramento, CA 95812 Re: Letter from Economists on the Proposed Regulation to Implement the California Cap-and-Trade Program Dear Chairwoman Nichols and Members of the Board: We commend the California Air Resources Board We commend the California Air Resources Board (CARB) for its vision and leadership in the design of the proposed cap and trade regulation. An emission cap, combined with a range of regulatory and market-based implementation mechanisms, provides clear incentives for changes in business practices and the development of new technologies. We applaud CARB for laying the groundwork for the largest carbon market in the United States. We support the maximum use of auctioning as the method of allocating allowances We recommend the maximum use of auctioning as the method of allocating allowances, subject to a short initial period of adjustment. Auctioning is preferable because it raises revenue for the State of California, it provides a sharper price signal, and it avoids conferring a competitive advantage on incumbent firms. We would support a modest amount of free distribution of allowances to a carefully considered subset of trade-exposed industries, subject to periodic review. We recommend a mid-course update of the identification of sectors singled out for special treatment due to potential leakage We support distributing free allowances only for the purpose of addressing emissions leakages associated with trade-exposed industries. However, CARB staff has noted that limitations on the availability of data and staff resources diminished the quality of the analysis that was performed to assess sectoral vulnerability. We, therefore, recommend that CARB complete a reassessment of leakage risk by 2014 and not specify how the protocol for special treatment of leakage would apply during the period 2015-2020. We recommend returning a significant portion of the allowance value to the people of California Although we expect the State to help finance investments designed to achieve low-cost emissions reductions, help adapt to climate impacts, help disadvantaged communities, and provide job training to acquire the skill sets needed for the new technologies and industries, the State should have flexibility in using the auction revenue. All of California will benefit from the improved health and lower pollution levels that will result from CARB’s implementation of California’s landmark legislation. We believe these policies can improve our energy security, create new business opportunities and more jobs, and provide incentives for innovation. Sincerely, -Original Authors- W. MICHAEL HANNEMAN, Ph.D. Chancellor’s Professor Department of Agricultural and Resource Economics University of California, Berkeley Berkeley, CA CHARLES KOLSTAD, Ph.D. Professor of Economics Department of Economics Bren School of Environmental Science and Management University of California, Santa Barbara Santa Barbara, CA JASMIN ANSAR, Ph.D. Western States Climate Economist Union of Concerned Scientists Berkeley, CA -Additional Signers- MICHAEL ANDERSON, Ph.D. Assistant Professor Department of Agriculture and Resource Economics University of California, Berkeley San Francisco, CA RICHARD ARNOTT, Ph.D. Distinguished Professor of Economics Department of Economics University of California, Riverside Riverside, CA KENNETH ARROW, Ph.D Stanford, CA Nobel Laureate, Economics BEVIN ASHENMILLER, Ph.D Professor Department of Economics Occidental College Los Angeles, CA MAXIMILIAN AUFFHAMMER, Ph.D. Associate Professor Department of Agriculture and Resource Economics University of California, Berkeley Berkeley, CA EDWARD BARBIER, Ph.D. John S. Bugas Professor of Economics Department of Economics & Finance University of Wyoming Laramie, WY CLAIR BROWN, Ph.D. Professor of Economics Director, Center for Work, Technology, and Society Institute for Research on Labor and Employment University of California, Berkeley Richmond, CA GARDNER BROWN, Ph.D. Professor Emeritus Department of Economics University of Washington Seattle, WA DALLAS BURTRAW, Ph.D. Washington, DC CHRIS BUSCH, Ph.D. Policy Director Apollo Alliance San Francisco, CA TRUDY ANN CAMERON, Ph.D. Mikesell Professor of Environmental and Resource Economics Department of Economics University of Oregon Eugene, OR RACHEL CLEETUS, Ph.D. Climate Economist Union of Concerned Scientists Cambridge, MA BOWMAN CUTTER, Ph.D. Claremont, CA EIRIK EVENHOUSE, Ph.D. Associate Professor Department of Economics Mills College Piedmont, CA MARVIN FELDMAN, Ph.D. Principal Economist Resource Decisions San Francsico, CA JAMES FINE, Ph.D. Economist Climate and Air Program Environmental Defense Fund Sacramento, CA ANTHONY FISHER, Ph.D. Professor Department of Agriculture and Resource Economics University of California, Berkeley Orinda, CA LEE FRIEDMAN, Ph.D. Professor, Goldman School of Public Policy University of California, Berkeley Berkeley, CA GALLO, Ph.D. Professor Emeritus Department of Economics California State University, Chico Chico, CA JOSHUA GRAFF ZIVIN, Ph.D. Associate Professor of Economics School of International Relations and Pacific Studies University of California, San Diego La Jolla, CA THEODORE GROVES, Ph.D. Professor Department of Economics University of California, San Diego La Jolla, CA STEVEN HACKETT, Ph.D. Professor Interim Associate Dean Department of Economics Humboldt State University Arcata, CA BRONWYN HALL, Ph.D. Professor Department of Economics University of California, Berkeley Berkeley, CA DARWIN HALL, Ph.D. Professor Department of Economics Department of Environmental Science and Policy California State University, Long Beach Long Beach, CA JANE HALL, Ph.D. Professor Department of Economics Co-Director, Institute of Economic and Environmental Studies California State University, Fullerton Laguna Beach, CA GEOFFREY HEAL, Ph.D. Professor Graduate School of Business Columbia University New York, NY CHARLES HOWE, Ph.D. Professor Emeritus Department of Economics University of Colorado,Boulder Boulder, CO LEA-RACHEL KOSNIK, Ph.D. Associate Professor Department of Economics University of Missouri-St.Louis St. Louis, MO DOUGLAS LARSON, Ph.D. Davis, CA NEIL LEARY, Ph.D. Carlisle, PA ERIN MANSUR, Ph.D. Associate Professor Department of Economics Dartmouth College Hanover, NH WADE MARTIN, Ph.D. Professor and Chair Department of Economics California State University, Long Beach Long Beach, CA PETER MEYER, Ph.D. President and Chief Economist The E.P. Systems Groups, Inc. Covington, KY DAVID MILLER, Ph.D Assistant Professor Department of Economics University of California, San Diego San Diego, CA BRUCE MIZRACH, Ph.D. Associate Professor Department of Economics Rutgers University Westfield, NJ NERMIN NERGIS, Ph.D. San Diego, CA DAVID NEWBURN, Ph.D. Assistant Professor Department of Agricultural Economics Texas A&M University College Station, TX RICHARD NORGAARD, Ph.D. Professor Energy and Resources Group University of California, Berkeley Berkeley, CA LON PETERS, Ph.D. Senior Energy Economist Union of Concerned Scientists Cambridge, MA MICHAEL REICH, Ph.D Professor Department of Economics University of California, Berkeley Berkeley, CA SIOBHAN REILLY, Ph.D Oakland, CA KURT SCHWABE, Ph.D. Associate Professor of Environmental Economics and Policy Department of Environmental Sciences University of California, Riveside Riverside, CA KRISTEN SHEERAN, Ph.D. Executive Director E3 Network Portland, OR KENNETH SMALL, Ph.D. Professor Emeritus of Economics University of California, Irvine Irvine, CA JOHN SORRENTINO, Ph.D. Associate Professor Department of Economics Temple University, Glenside, PA ROGER SPARKS, Ph.D. Professor Department of Economics Mills College Oakland, CA SEIJI STEIMETZ, Ph.D. Assistant Professor Department of Economics California State University, Long Beach Long Beach, CA STEVEN STOFT, Ph.D. Berkeley, CA WILLIAM SUNDSTROM, Ph.D. Professor Department fo Economics Santa Clara University Palo Alto, CA SCOTT TEMPLETON, Ph.D. Associate Professor Department of Applied Economics and Statistics Dept. Of Applied Economics And Statistics Clemson University Clemson, SC TOM TIETENBERG, Ph.D. Mitchell Family Professor of Economics, Emeritus Department of Economics Colby College Waterville, ME ANTHONY WESTERLING, Ph.D. Associate Professor Sierra Nevada Research Institute University of California, Merced Mariposa, CA |
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| Date and Time Comment Was Submitted | 2010-12-15 10:07:47 |
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