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Comment 34 for 2013 Investment Plan for Cap-and-Trade Auction Proceeds (2013investmentpln-ws) - 1st Workshop.
First Name: Chuck
Last Name: Shulock
Email Address: shulockconsulting@comcast.net
Affiliation:
Subject: Additional points to consider in Draft Concept Paper
Comment:
The investment plan should incorporate the following points. More detailed comments are provided in the attachment. 1. The list of potential uses of funds should be expanded to include the return of auction proceeds to households and/or to offset business taxes. 2. The Governor and the Legislature should establish on a policy basis the aggregate amount of funds to be allocated to short term projects, long term projects, and the return of auction proceeds to households and/or to offset business taxes. Proposals should compete within each category but not across categories. 3. To minimize the potential for legal challenge all funded projects (other than the return of funds to households or businesses) should result in greenhouse gas reductions. 4. In general auction proceeds should be used to reduce overall compliance costs rather than achieve additional reductions beyond those identified in the Scoping Plan. 5. Funding to support near-term reductions (a) should only address emissions from sources not covered under the cap, or sources under the cap that do not respond to the price signal imposed by the cap, (b) should be prioritized based on cost-effectiveness, and (c) should only be provided to projects that achieve reductions at a cost per ton lower than the allowance value (except as modified for SB 535 purposes as noted in the attached detailed comments). Reductions from sources not under the cap should be treated as offsets, or alternatively additional allowances should be created within the cap in an amount equal to the reductions achieved from the uncapped sources. 6. Long term strategies should focus on transport electrification, VMT reduction/land use, and energy efficiency/renewables, and should be evaluated on the basis of return on investment (cost/benefit analysis), taking into account the full range of societal and private benefits accrued.
Attachment: www.arb.ca.gov/lists/2013investmentpln-ws/45-response_to_arb_request_for_public_input_on_draft_concept_paper__shulock.docx
Original File Name: Response to ARB Request for Public Input on Draft Concept Paper, Shulock.docx
Date and Time Comment Was Submitted: 2013-02-27 11:19:45
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