First Name | Carlos |
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Last Name | Davidson |
Email Address | carlosd@sfsu.edu |
Affiliation | San Francisco State University |
Subject | comment on auctioning, offsets and low income impacts |
Comment | Comments to ARB on proposed scoping plan Carlos Davidson Associate Professor/Director Environmental Studies Program San Francisco State University November 19, 2008 I commend the ARB staff for depth of work and the comprehensive nature of the plan. While it might be possible to get to the 2020 goals with more focused and deeper emissions cuts, a comprehensive approach is a necessity to put us on a path to reach the need 2050 goals. I also commend the ARB for the public health and economic analyses that accompany the scoping plan. As a result of these analyses it is great to see that the scoping plan will result in overall improvements in public health and net economic benefits. In addition to the aggregate economic analysis it would be good to see analysis of distributional impacts - will low income people bear a disproportionate burden? Will they be able to realize the energy efficiency savings in transportation and in residential energy. or will those savings only be reaped by higher income brackets? If there is a disproportionate burden on lower income Californians then I would like to suggest that ARB pursue the scoping plan suggestion to use auction revenue to mitigate that burden. If auction revenue was used to give additional incentives to low income Californians to switch to fuel efficient cars, insulate homes, install solar power or water heaters, and subsidize public transit, it would help reduce the financial impact of rising energy prices. And it would provide two additional benefits: it would encourage further emissions reductions than would be possible without these programs, and it would help ensure that “being green” is not perceived as something only for the more well to do. To reach our goals beyond 2020 we need a broadly accepted culture of striving for reduced emissions. The plan is way to timid in its approach to allowance auctioning. It acknowledges the many good reasons to have 100% auctioning but then simply calls it a worthwhile goal, with no commitments or no timelines. The Greenhouse Gas Initiative in the northeast started out with 100% auctioning. California should do the same. At a minimum the plan should at least start with 50% and have a firm commitment to reach 100% in a few years. Allowing 49% offsets in meeting emissions allowances is counterproductive. The failure of the Clean Development Mechanism offsets has shown that establishing additionality is difficult. There are huge financial incentives for deception. This means that offsets will require costly design, enforcement and monitoring effort – effort that could be better placed into direct real emissions reductions. I would urge the ARB to limit the use of offsets to 10% of emissions allowances. Thank you for considering my comments. |
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Date and Time Comment Was Submitted | 2008-11-19 09:46:17 |
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