First Name: | Nick |
---|---|
Last Name: | Despota |
Email Address: | nick@lumina-media.com |
Affiliation | |
Subject | Comments on 2030 Target Scoping Plan Discussion |
Comment |
Given that: 1. Achieving the 2030 target will be significantly more difficult than achieving the 2020 target; 2. Large emitters of GHGs were more likely to use offset credits for projects outside the state of California to meet their obligations under cap-and-trade. (See, A Preliminary Environmental Equity Assessment of California’s Cap-andTrade Program; Cushing, Wander, Morello-Frosch, et al.; USC, UC Berkeley. 2016. Attached.) 3. Cap-and-trade allows sources to achieve compliance without necessarily reducing actual physical emissions. 4. Consequent to 2 and 3 above, while overall, GHG emissions in the state have continued to drop, many industry sectors covered under cap-and-trade report increases in localized in-state GHG since the program came into effect in 2013. 5. Emission of GHG gasses co-vary with those of other toxic air contaminants and particulate matter. 6. AB 197, Section 5, authorizes direct regulation to protect the state’s disadvantaged communities, which have been shown to suffer disproportionately from refinery emissions. Therefore, I urge that the Scoping Plan incorporate provisions for regional air districts to enact direct caps on refinery and other large stationery sources, to prohibit exceedances beyond an average of emissions of recent years for each facility. The facility limit should ramp down sharply in subsequent years as national dependence on fossil fuels for transportation and other purposes decline, and as required to insure achievement of the 2030 target. I appreciate this opportunity to comment on the 2030 Scoping Plan. |
Attachment |
www.arb.ca.gov/lists/com-attach/8-sp2030disc-dec16-ws-BWZcNlM7WWcKbQF1.pdf Original File Name: Climate_Equity_Brief_CA_Cap_and_Trade_Sept2016_FINAL2.pdf
Date and Time Comment Was Submitted: 2016-12-13 19:04:31 |
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