SOLUTIONS A strong AB 32 Scoping Plan

June 16, 2008

The Honorable Arnold Schwarzenegger
Governor of California
State Capitol Building
Sacramento, CA  95814

Mary Nichols
Chairperson, California Air Resources Board
1001 I Street
P.O. Box 2815
Sacramento, CA  95812

RE:   AB 32 Scoping Plan

Dear Governor Schwarzenegger and Chairperson Nichols:

As the California Air Resources Board (CARB) grows closer to completing its monumental task of creating a Scoping Plan describing how the state will reach its goal of reducing global warming pollution nearly 30 percent by 2020, the Union of Concerned Scientists strongly encourages you to include three important elements in this plan. These elements are not only essential for enabling California to reach its 2020 climate goal, but also ensure that our state is on a path toward the much greater global warming emission reductions needed by 2050, as outlined in the governor's executive order of June 1, 2005. By incorporating these three critical items in its larger package of climate policies, CARB will ensure that significant clean technology advances and emission reductions are made in the state's highest-emitting sectors: transportation and electricity.

The Scoping Plan should include the following:

1) A compelling request to the California legislature to give CARB the authority and direction to implement a vehicle feebates, or clean car discount, program.  Such an incentive program would create one-time rebates and surcharges on new passenger cars and trucks based upon their emissions of global warming pollution. The rebates and surcharges act as incentives for consumers to purchase, and for manufacturers to produce, cleaner, lower-emitting vehicles. Research by University of Michigan shows that, in conjunction with California's current vehicle global warming standards, a fully implemented feebates program can reduce global warming pollution from the tailpipe of new vehicles by an additional 21 percent.

2) A compelling request to the California legislature to increase the state's renewable portfolio standard (RPS) to 33 percent by the year 2020.  UCS experts estimate that increasing the percentage of our electricity that comes from renewable sources to 33 percent by 2020 will cut approximately 13 million metric tons of global warming pollution. At the same time, the standard could reduce harmful NOx and particulate matter pollution by thousands of tons.

While a 33 percent RPS will reduce more global warming emissions from the electricity sector than any other policy, it also has many other vital benefits, including:

• Stimulating clean technology and investment and strengthening California's burgeoning clean tech industry
• Diversifying the state's energy supply and helping to protect consumers from natural gas price volatility
• Providing market certainty for renewables developers and promoting long-term planning in the infrastructure needed to support high levels of renewable energy development

3) A commitment to carefully and rigorously limit the use of compliance offsets.  Offsets allow polluters to avoid making emission cuts themselves by paying for pollution-reducing projects elsewhere. Putting smart limits on the ability of California global warming emitters to "outsource" their efforts to reduce emissions through the purchase of offsets will lead to many benefits. It will help direct the flow of investment to green energy and other clean tech global warming solutions in California's high-emitting sectors (transportation and electricity). This will not only help make immediate reductions in California's global warming pollution, but also help reduce emissions worldwide as new and innovative technologies developed in California are exported globally. Carefully limiting offsets to focus on those that will simultaneously reduce global warming pollution and toxic and smog-forming air pollutants will allow Californians to benefit from cleaner air.

If offsets are used in a cap and trade system, they should be limited to a very small fraction of required reductions. Any offsets that may be allowed in California should occur within California's un-capped sectors, so that the reductions due to a cap are not counted twice. If the offsets used are from other regions, such as those states in the Western Climate Initiative, they should be in regions that have adopted strong global warming caps so that the offsets can be tracked and verified.

Thank you for the good work you do and for taking our ideas into serious consideration.  We look forward to working with you throughout the AB 32 implementation process. 

Sincerely,

Patricia Monahan
UCS California Office Director

Dan Kalb
California Policy Coordinator