Comment Log Display

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.

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