AB 32 IMPLEMENTATION GROUP
Our coalition represents large and small businesses
that are vital to California’s economy and that
provide hundreds of thousands of jobs.
Our Mission is to be a constructive voice in the process
to implement AB 32 (The Global Warming Solutions
Act) and ensure that the greenhouse gas emission
reductions required are achieved while maintaining
the competitiveness of California businesses
and protecting the interests of consumers and
workers.
AB 32 should be implemented
consistent with these Eight Principles:
1. Provide Regulatory
Certainty
2. Adopt Policies
that Keep Jobs in California and Achieve
Global
Emission Reductions (Leakage)
3. Use Sound Scientific
Methods of Review
4. Impose Only
Cost-Effective & Technologically Feasible Regulations
5. Promote Innovation
and Market-Based Strategies
6. Minimize and
Fairly Allocate Compliance Costs
7. Link to Regional and National Climate Policy Initiatives
8. Coordinate AB 32 with Existing Air and Environmental Quality Standards
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QUICK LINKS
AB 32 Implementation Group letter commenting on CARB's Administrative Fee Regulation Draft Regulatory Language. AB 32 Implementation Group remains very concerned that the fee proposal does not meet basic standards for a valid Administrative Fee" -- April 24, 2009
Preliminary Review of the CARB Staff Analysis of the Proposed Low Carbon Fuel Standard (LCFS)
The LCFS to be adopted next week by CARB would, by 2020, increase fuel costs by $3.7 billion a year and increase smog-forming chemicals by five tons a day, says a just-released independent economic analysis of the program.
Letter to CARB urging the economic analysis be completed by June 30, 2009
(April 17, 2009)
"The economic analysis should be the cornerstone of the policymaking process rather than an addendum to the regulation process."
Letter to Governor Schwarzenegger regarding enhanced vapor recovery regulation and Low Carbon Fuel Standards (April 17, 2009)
Letter to CARB regarding Low Carbon Fuel Standards ( March 30, 2009)
Expressing serious concern about the state's plan to press on with a reformulation of California's transportation fuels, this letter states the staff report on the new standard is 'seriously deficient on both economic and environmental grounds.'
VIDEO: Stakeholder Comments to the California Air Resources Board regarding the AB 32 Scoping Plan.
Why CARB Needs to Take the Time to Implement AB 32 Correctly
State decision-makers should require that CARB take the time necessary to satisfy all of the AB 32 criteria. Before proceeding with adoption of any regulations, CARB should redo its AB 32 scoping plan economic analysis to address the major flaws identified by its peer reviewers, the LAO and stakeholders.
AB 32 IG's comments to CARB proposed administrative fee regulation for implementing AB 32 (Feb. 13, 2009)
AB32IG Letter to CARB RE: Additional Comments on Preliminary Draft Staff Proposal on Recommended Approaches for Setting Interim Significance Thresholds for Greenhouse Gases under CEQA
Peer Review of AB 32 Scoping Plan
Nonpartisan Legislative Analyst's Office Identifies Weaknesses in CARB's Economic Analysis
