First Name | Edward |
---|---|
Last Name | Mainland |
Email Address | emainland@comcast.net |
Affiliation | Sierra Club California |
Subject | Sierra Club Comment on Voluntary Actions, Allowances and Revenues, and Evaluations |
Comment | COMMENTS ON AB 32 PROPOSED SCOPING PLAN, SUBMITTED BY SIERRA CLUB CALIFORNIA, November 19, 2008 E. VOLUNTARY EARLY ACTIONS AND REDUCTIONS (p. 67) • Sierra Club is pleased CARB is studying means to reward voluntary early actions reductions. F. USE OF ALLOWANCES AND REVENUES (p. 69) • We support most of the uses listed, particularly those related to environmental justice, such as “achieving environmental co-benefits.” However, we are not supportive of “direct refund to consumers,” unless such “refunds” can be tied directly to GHG reductions. • Criteria and toxic air pollutants create health risks, and some communities bear a disproportionate burden from air pollution. We support ideas that benefit these unfairly impacted communities. • Revenues should be prioritized for projects that reduce both GHG emissions and also provide reductions in air and other pollutants that affect public health. • We are pleased that CARB has provided a positive discussion of carbon fees. We think that the range of $10 and $50/ton would be reasonable; this fee could start low and gradually increase over time as needed. • A $30-per-ton fee on all greenhouse gases would provide revenue of approximately $12 billion per year, which is less than 1/100th of the California economy. This money could be restored immediately to the state economy, encouraging local investment in clean technologies and green jobs, activities with a bright prospect in a carbon-constrained world. Revenues could also provide rebates for low-income consumers. • We believe that it should be possible to quantify some of the benefits from the expenditure of the funds on projects that provide considerable GHG emission reductions. For example, transit operators know increased frequency of service and lower fares can increase ridership. Recovering waste heat, either to generate electricity or from generating electricity, has specific value to commercial and residential utility customers. • On carbon pricing, emissions fees should be analyzed along with a cap-and-auction system, as the Plan proposes. We need the income to fund CO2 reductions. • Polluters always should have to pay for cleaning up the damage they cause. Therefore, if a carbon market is established, all emission allowances should be auctioned. The Plan states (page 16), “These allowances could be freely distributed to capped firms or auctioned in the trading market.” We are opposed to free distribution of allowances, since they don’t encourage accountability and provide much less motivation to reduce GHG emissions. • Major emitters should pay for the cost of administering this program. III. EVALUATIONS (p. 73) Specific economic benefits of energy efficiency and clean energy measures can be evaluated based upon the sum of: 1) Projected and avoided costs for these energy supplies, 2) In-state jobs and manufacturing due to green economic activity, 3) Federal tax credits benefits and in-state tax revenues, 4) Export revenues, and 5) Environmental and public health benefits. • CARB’s analysis of public health benefits of transportation efficiency measures focuses only on respiratory medicine and economic benefits of reducing respiratory disease. While this analysis provides powerful support for the Plan’s vehicle and fuel improvements, the Plan overlooks large public health benefits to other transportation efficiency measures not in the Plan. • Public health perils such as obesity, diabetes and heart disease can be reduced by strategies the Plan should embrace more aggressively. Auto-dependent neighborhoods make these diseases more common; smart growth and reduced vehicle miles traveled can help combat them. • CARB’s public health analysis needs to address the issue of food security and “healthy food deserts.” Lacking local healthy food choices, many people must travel long distances to obtain more healthy fare or rely on expensive, locally available junk food. Although emissions benefits of better access to healthy food may be modest, public health benefits can be significant and climate change policy offers a chance for low-income “food deserts” to get attention. |
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Date and Time Comment Was Submitted | 2008-11-19 19:22:04 |
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