Comment Log Display

 

August 11, 2011

Clerk of the Board
California Air Resources Board
1001 I Street
Sacramento, California 95814

Re: Comments on CARB Modified Text for the Proposed California Cap
on Greenhouse Gas Emissions and Market-Based Compliance Mechanism
Regulation

Dear California Air Resources Board Members:

The California Farm Bureau Federation appreciates  the opportunity
to submit comments on the Proposed California Cap on Greenhouse Gas
Emissions and Market-Based Compliance Mechanism Regulation.  
The proposed cap-and-trade program will have significant impact on
California’s family farms and ranches because they utilize the
products and services of many of the entities subject to the
mandatory greenhouse gas emission reductions. The fuel and
electricity providers that provide our energy inputs and the food
processors that add value to the numerous agricultural commodities
grown in California will have to pass along their price increases
to achieve their GHG reductions.  
One of our key remaining concerns is that we believe the formula
for trade exposure and emissions leakage should be reevaluated to
recognize the complexity and impact of agricultural import and
export markets.  Food processing should be moved to the “high”
leakage risk category, due to increasing competition from
international and domestic markets. 
Food manufacturing is located in the second Industry Assistance
Factor and should be moved to the top industry assistance factor
tier.  The Industry Assistance Factor is essentially the ability an
industry has to pass-on carbon costs.  With low-cost competitors
throughout the world, even a minimal increase in cost could
displace local U.S. markets, giving more ground to domestic and
international competitors.
California grows and processes approximately 90% of all U.S.
processing tomatoes.  However, China is now the world’s second
largest producer, nearly doubling its crop size over the past few
years.  Additionally, China has tripled its processed peach exports
from 2006-2010.  Any fraction increase in price will put our local
farmers at a further disadvantage.
The California agricultural community is diverse and our issues
span the entire journey from the farm to the fork. We appreciate
your attention to our concerns from a production agricultural
perspective in addition to the needs of many of our 400 commodities
that require handling or processing.

Sincerely, 
 
Cynthia L. Cory
Director, environmental Affairs