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Comment 14 for 2016 Amendments to the Clean Power Plan Compliance Effort (111dcompliance-ws) - 1st Workshop.
First Name: David
Last Name: Schonbrunn
Email Address: David@Schonbrunn.org
Affiliation: TRANSDEF
Subject: Comments on the Clean Power Plan Discussion Paper
Comment:
After reviewing the Clean Power Plan Compliance Discussion Paper, we offer the following comments: While our organization has long been involved in ARB climate change processes and generally supports ARB's efforts to reduce GHGs, we have never been supporters of Cap and Trade. We continue to be concerned about the abstruseness of the regulatory structure--no one besides the lawyers involved really understands it--as well as its potential to be gamed. We were strong advocates of a carbon tax in our comments on the first Scoping Plan, and continue to see its superiority, especially after its real-world success in British Columbia. We suggest that a carbon tax be adopted as the backstop mechanism for the Clean Power Plan. It would not be triggered unless a massive policy failure, such as widespread gaming, occurred or there is a failure of nerve by either the Legislature or the Board. A carbon tax in the backstop position would act as a strong deterrent to gaming or backsliding, because of its unquestioned effectiveness. BTW, we found the following sentence impossible to understand: "For California, U.S. EPA calculated a final statewide mass goal in the 2030-31 period of 96.8 million short tons of CO2 (e.g., 48.4 million short tons, approximately, in 2030)." It is entirely non-obvious why half the mass goal is stated in parentheses. Please either clarify or correct the text. To further inform stakeholders, it would be useful to calculate the actual emissions reduction percentage for CA EGUs, using the EPA mass goals. Thank you, David Schonbrunn
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Date and Time Comment Was Submitted: 2015-12-03 14:54:03
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