Re: Proposed Amendments to the California Cap On Greenhouse Gas Emissions and Market-Based Compliance Mechanisms Regulation

In order to meet our state’s greenhouse gas emissions goals, it is essential that the California Air Resources Board (CARB) reduce the emissions cap used in California’s cap and trade (C&T) program. As has been reported by independent analyses, the annual caps through the year 2030 are actually higher than current projected emissions.1,2,3 This over-allocation of credits means that the cap and trade program will likely end up having no effect on state emissions at all.

In other words, assuming that the C&T program didn’t exist, emissions from the covered sectors would already be lower than the proposed caps leading up to 2030. It’s as if a law stated that you were allowed to pollute 100 units next year, even though your best analysis predicts that you weren’t going to pollute more than 90 units to begin with. Such a law would have no effect on behavior. The correct remedy would be to set the allowed pollution rate to something like 80 units—otherwise you would simply continue to pollute at 90 units annually.

The IPCC has estimated that annual emissions need to be reduced by around 50% by 2030 to avoid catastrophic effects due to climate change. Since GHGs remain in the atmosphere to up to thousands of years, more emissions in this decade will mean we need to make deeper reductions later, even needing to go to negative emissions. It is crucial that California meet our targets in this decade, especially since our state is on the forefront of this effort.

Though the first C&T priority must be for CARB to reduce emissions caps, we also urge state lawmakers to create additional stronger local caps on concentrations of toxins and particulates from fossil fuel combustion.

We are residents of California, aware of our unparalleled role on the front lines of the climate war. There is no other American state that has a size, reputation, regulatory reach, and innovation ecosystem that can counteract the federal government’s abhorrent climate policies.

Therefore we have a unique responsibility to get the policies right. We request that (a) CARB lower emissions caps to a level that will ensure that we meet emission 2030 emission goals  and that (b) CARB consider additional rules to address the inadequacies in protecting health among local communities. This is about more than just emissions from the Golden State itself—the rest of the world relies on us to set a new gold standard for climate policies, which we can begin to do by fixing the serious flaws in current policy.

  1. http://wp.nearzero.org/wp-content/uploads/2018/07/Near-Zero-comment-letter-June-2018-workshop.pdf
  2. https://calmatters.org/articles/checking-the-math-on-cap-and-trade-some-experts-say-its-not-adding-up/
  3. https://lao.ca.gov/Publications/Report/3719




In the cap-and-trade system, major polluters must either produce fewer greenhouse gases to comply with California’s emissions caps or buy credits to offset their excess emissions from companies that pollute less. Credits are traded at state-sanctioned auctions and on secondary markets. And the state gives some free to utilities, natural-gas suppliers and industries that are vulnerable to out-of-state competition.

Some companies have not yet needed to use up the allowances to stay within state emissions limits and probably won’t have to in the next couple of years, according to some analysts, who estimate there are hundreds of millions of unused credits in the system.

The result is a glut of credits that could allow businesses to keep polluting past state limits in later years, after the overall cap becomes more restrictive. Unless the oversupply is addressed, experts say, polluters will have no incentive to cut emissions to required levels by 2030; instead, industries could continue polluting and use banked allowances to offset their emissions and technically keep them under the cap. [https://calmatters.org/articles/checking-the-math-on-cap-and-trade-some]

Further, there are no cap on local toxins effecting the communities where the polluters reside. This is a critical missing piece of this cap and trade bill and needs to be changed to protect citizens living in these geographic areas.

The California Air Board is accepting comments from the public until October 22, 2018. We will deliver this letter to CARB by the deadline.


More information:

Near Zero's Comment Letter to CARB: LINK 

Article by Julie Cart, Cal Matters: LINK

Legislative Analyst's Office report: LINK

Fill out the form below to sign the public comment letter to CARB:


CuriOdyssey , Rachel Meyer, Executive Director
Peninsula Interfaith Climate Action , Debbie Mytels, Chair
Transition Palo Alto , Jan Rubens, Leader
Carbon Free Palo Alto , Bruce Hodge, Chair
Mothers Out Front , Adelita Serena, Climate Action Organizer
Carbon Free Silicon Valley , James Tuleya, Board Chairperson
Silicon Valley Courageous Resistance , Cheryl Weiden, Lead, Environmental Interest Group
Fossil Free Mid-Peninsula , Carol Cross, Co-Convenor
Minerva Ventures , Marianna Grossman, Managing Partner
ZW Block Leader , Shannon McEntee,