First Name | Judy |
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Last Name | Moores |
Email Address | jemoores@aol.com |
Affiliation | |
Subject | CA Cap and Trade on GHG Emissions - please revise and phase out free allocation |
Comment | Chairman Nichols and Members of the Board: Your work as part of the California Air Resources Board (CARB) implementing the Global Warming Solutions Act (AB 32) is critical to the health of our state, its people, and its plants and animals. Now is the time for bold action. While I agree with many of the steps outlined in the AB 32 Scoping Plan, I am very 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. With the resounding defeat of Prob 23, you have a mandate to take the much-needed and critical actions and removie the massive allowance giveaways outlined in the current rules. Thank you. |
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Date and Time Comment Was Submitted | 2010-12-12 15:46:05 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.