First Name | Sibylle |
---|---|
Last Name | Scholz |
Email Address | sibyllescholz@gmail.com |
Affiliation | Private Citizen |
Subject | Transparency in your ZEV probram |
Comment | Madam/Sir I am writing to express my concern over the State of California's (SOC) policy regarding its ZEV program. To date, the SOC has denied the public access to automaker credit trading information. As an economist I find this behavior alarming, as it leads to less than optimal markets. A trading market, such as that set up in the ZEV program, is designed to facilitate compliance in the most efficient manner possible. For some automakers, producing zero emission vehicles is easier, cheaper, or within their product plans. They can sell ZEV credits to those automakers whose ZEV production will take longer or for which it is more expensive to produce such vehicles. However, the benefits of a trading market are gained only when both buyers and sellers have full information. Allowing trades to be kept confidential facilitates price fixing and collusion, hampering the efficient functioning of the market and distorting the pollution reduction goals of the ZEV program. Allowing confidential trading also prevents the public from overseeing and ensuring a non-fraudulent market. In order for the SOC to fully implement the ZEV program, it needs to make public all information on credits it currently holds confidential. The importance of fully open trading markets in every credit trading system cannot be sufficiently stressed. This same Board is considering the creation of a pollution credit trading system for greenhouse gas emissions. Trading pollution credits is only possible in an open market such as we see at the Chicago Climate Exchange (CCX). Maintaining secrecy of trades not only limits market opportunities but can hurt business. These principles are extremely important as the State moves toward adopting a pollution trading system for greenhouse gas emissions. Setting a state precedent for withholding credit trading information will hamper the effectiveness of a greenhouse trading market. The importance of open trading markets was recently signaled by the Chairman and CEO of the Chicago Climate Exchange, Dr. Richard L. Sandor: "We congratulate the pioneering initiative of the great State of California, the legislature and the people of California and know that implementing any emissions trading that may ensue will require price transparency and efficient, exchange-based systems for maximum success." I fully agree with Chairman Sandors' basic assumption regarding the need for transparency in such a system. In summary, I urge you to disclose fully all information you have as it relates to emission credits you hold for automakers. Respectfully, Sibylle Scholz, PhD Agricultural Economist |
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Date and Time Comment Was Submitted | 2008-03-20 14:00:49 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.