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While I agree with many of the steps outlined in the AB 32 Scoping
Plan, I am concerned by the over-allowance of free pollution
credits to the industrial sector in the Cap & Trade Design. I urge
you to revisit, revise, and phase out free allocation to the
industrial sector. The proposed level of free allocation to the
industrial sector is likely much higher than is needed to combat
leakage. Several research studies have found that the “leakage”
claims of the industrial sector are exaggerated and subsidizing
these industries through free allowances creates barriers to
transitioning to a cleaner economy. CARB should build in an
explicit adaptive management process to adjust the free allocation
to the industrial sector based on specified evaluation metrics.

Please take advantage of the favorable public climate that
California currently enjoys around addressing climate change and
implementing AB 32 by taking much-needed bold actions and removing
the massive allowance giveaways outlined in the current rules.
Thank you.