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To CA ARB

As a supplement to my previously submitted comments, I also wish to
submit for the record this article by Darien Shanske concerning
state-level Border Tax Adjustments for prospective carbon taxes. 

The legal theory propounded and explored by Shanske addresses
direct carbon tax mechanisms at the state level that would
alleviate, minimize, and perhaps eliminate altogether, GHG
"leakage" concerns. 

This material should be considered in conjunction with the
previously submitted material in Springmann et al (2016), as CA ARB
develops a Cap and Tax alternative to Cap and Trade. 

Again, such a Cap and Tax alternative should apply to the
Agricultural economic sector and should address frequently-voiced
concerns about GHG "leakage" that might occur if high-GHG-polluting
industries (and the direct consumers of theses industries'
commodities) are required in the future to "internalize" the social
and environmental costs of commodity production that are currently
being "externalized" to the broader society and environment. I
would argue that Shanske provides the legal map for instituting,
implementing, enforcing, and collecting state-level carbon taxes in
a manner that will minimize GHG "leakage" in the future.

Sincerely,

Todd Shuman, Camarillo

Original File Name: Shanske BTA Carbon Tax.pdf

Date and Time Comment Was Submitted: 2016-12-16 16:03:26