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Comment 5 for Analysis to Identify Potentially Significant Environmental Effects of Proposed Cap-and-Trade Regulation (aug-23-fed-ceqa-ws) - 1st Workshop.


First Name: Patti
Last Name: Krebs
Email Address: iea@iea.sdcoxmail.com
Affiliation: Industrial Environmental Association

Subject: CEQA Scoping Meeting Cap-and-Trade Regulation
Comment:
Thank you for holding the California Enviornmental Quality Act
Scoping Meeting for the Proposed Can-and-Trade Regulation on August
23, 2010.

I would like to submit the following comments:

*Compliance Instruments:

-Analyze effects of increasing amount of available offsets (beyond
the 4% proposed or 8% at certain price point)

-Analyze broader use of offsets to include international resources

-Consider cap-and-trade program impacts based on actual (not
potential) Western Clilmate Initiative (WCI) partners who have 
formally ratified participation at time of analysis

*Leakage:

-Analyze Medium and Low Risk categories of businesses (as required
by CEQA to look at projected impacts) and reassess their
significant and "high" potential to relocate their operations, or a
portion of their operations, to other states or internationally.
 
*Research and Development:

-Representing an area with significant research and technologoy
development activities, analysis needs to be conducted on how these
R&D activities will be treated in overall facility emission
limitations and whether they will be subject to the
cap-and-trade/offset program requirements.  

*Localized Impacts:

-Global warming is an international concern, and the
cap-and-trade/offsets program should not be considered in the
context of localized air quality health-related issues.

-Limitations or restrictions of the cap-and-trade/offsets program
should not be linked to local air quality district boundaries, and
criteria pollutants should continue to be addressed within only the
existing regulatory framework.  

Patti Krebs, Executive Director
Industrial Environmental Association
110 West "C" Street, #900
San Diego, CA  92101   

Attachment: www.arb.ca.gov/lists/aug-23-fed-ceqa-ws/8-iea_logo-blue_and_white.jpg

Original File Name: IEA Logo-BLUE AND WHITE.JPG

Date and Time Comment Was Submitted: 2010-09-10 15:07:22



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