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Thank you for taking global climate change seriously. A plan to
reduce pollution while rebuilding jobs is not only good for
California, it is good for all of America and the world. There are
some suggestions for making the CARB program even stronger, which
have been presented by the Union of Concerned Scientists. Please
consider their suggestions as you go forward.

These suggestions include:
1. Commit to maximize the use of auctioning as a method of
allocating allowances.
2. Create dynamic product output based benchmarks that reflect best
practices in the sector.
3. More clearly define CARB's role in offset decisions.
4. Ensure that offsets cannot be sold more than once through
different registries.
5. Lower the offset limit.
6. Increase transparency.
7. Require allowance vlaue allocated to utilities to benefit
ratepayers, meet the objectives of AB 32, and facilitate emission
reductions above and beyond BAU.

Thank you.