Comment Log Display

Our state's leadership in developing and implementing a cap on the
pollution that causes global warming will likely have ripple
effects throughout the nation and the world.  Because the CA
cap-and-trade program may become a model for other states and the
feds, it is important that the program is designed to
cost-effectively maximize emission reductions in the
higher-emitting sectors.  I appreciate the ARB for the public
process that has led to the proposed regulation and the opportunity
to provide these constructive comments. 

The Rule should be modified to incorporate the following: 

 ** Clearly commit to maximize the use of auctioning as the most
economically logical method of allocating emission allowances. 

 ** Create dynamic product output-based benchmarks that reflect
best practices in each given sector. 

 ** Better identify and define CARB’s role in 'offset' decisions. 

 ** Ensure that 'offsets' cannot be sold more than once through
different registries. 

 ** Lower the offset limit because it is way too risky to allow
huge volumes of 'offsets' early in the program.  

 ** As enforcement progresses, increase transparency.

 ** Require allowance value allocated to utilities to benefit
ratepayers, meet the objectives of AB 32, and facilitate emission
reductions above and beyond business as usual.