First Name | Edward |
---|---|
Last Name | Mainland |
Email Address | emainland@comcast.net |
Affiliation | Sierra Club California |
Subject | Sierra Club's Overall Comments on Scoping Plan |
Comment | COMMENTS ON AB 32 PROPOSED SCOPING PLAN, SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008 OVERALL COMMENTS: • We are pleased that the Proposed Plan seeks to meet the law’s requirement of rolling back our greenhouse gas emissions to 1990 levels by 2020. • Scientists now suggest, however, that goal of 1990 levels by 2020 may be inadequate. The Plan now wisely incorporates intentional redundancies and a “margin of safety” that could anticipate the possibility that urgent action is more pressing than current assumptions would indicate. The GHG concentration in the atmosphere may be at the tipping point, as evidence of the newly recognized rapid release of arctic permafrost and seabed methane gives us even less time for GHG reductions before runaway warming takes over. • We welcome this Plan’s statement that California cannot afford delay in reducing pollution that causes global warming. The potential costs of inaction or delayed action are immeasurably greater than the cost of implementation now. • CARB's plan, which relies predominately on direct regulations for the electricity and transportation sectors to reach the state's 2020 emission reduction goal, sets a standard for other states and the federal government in most areas. However, there are substantive flaws in the plan’s approach to “cap-and-trade” and “offsets.” • Sierra Club strongly supports the new plan's promises to cut more emissions than previous drafts did. We also support the plan’s proposal to include: auctioning of emission allowances to polluters; more limitations on offsets; recognition of much higher potential for recycling and zero waste; more momentum for significant changes in current land use and transportation planning; and more emphasis on green job creation in the fields of clean power and energy efficiency. The Plan now makes a stronger case for the economic and health benefits of clean energy. • The Plan correctly points out that many powerful parallel policies must be pursued in order to remove all the state's market barriers and regulatory impediments to GHG reduction. State climate programs need the full force of CARB’s backing to such parallel measures as Feed-In Tariffs, Carbon Fees and Community Choice Electricity • We support the inclusion of co-benefits from GHG reductions such as public health improvements and better energy efficiency. |
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Date and Time Comment Was Submitted | 2008-11-19 18:19:12 |
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