WHAT WE'RE SAYING

November 4, 2008
Comments to CARB on the Final Scoping Plan
Specific recommendations for how CARB should proceed

October 24, 2008
Letter to the California Energy Commission RE: GHG emissions under CEQA

October 23, 2008
Letter to CARB Chair, Mary Nichols, commenting on the Economic Analysis Supplement to the Draft Scoping Plan and Analysis Group report on CARB’s Economic Analysis.

September 23, 2008
Letter to Governor Schwarzenegger RE: Principles for Implementing a Successful Low Carbon Fuel Standard

August 15, 2008
Our comments on the Western Climate Initiative draft design of the Regional Cap and Trade Program
AB 32 IG wants to ensure the Program is developed in a way that helps members manage operating costs by increasing energy efficiency efforts and deploying more renewable energy projects. To do this it is imperative that a robust and fair carbon offset market be created that encourages voluntary participation.

August 6, 2009
Letter to CARB Chair, Mary Nichols, commenting on Draft Scoping Plan
We are very concerned about the draft Scoping Plan’s impact on the California economy. Failure to address the above concerns risks severe unintended consequences for our state’s economy and the potential failure of the entire AB 32 program.

June 9, 2008
Letter to CARB Chair, Mary Nichols, regarding the development of the Scoping Plan and Policy Comments

May 9, 2008
Letter to CARB on Cost Containment for AB 32

April 21, 2008
Letter to CARB Research and Economics Studies Branch commenting on the role offsets should play in the implementation of AB 32.

April 16, 2008
Letter to Chuck Shulock of CARB following up on our meeting regarding the low carbon fuel standard.

March 19, 2008
Letter to Gov. Schwarzenegger urging his continued support of market-based solutions to reducing carbon emmissions.

March 5, 2008
Letter to Bay Area Air Quality Management District on proposed fees for district climate change activities

February 27, 2008
Letter to Gov. Schwarzenegger and CARB Board on Attorney General's Local Activities
Letter supporting the orderly implementation of AB 32 instead of the chaotic manner in which the AG's recent actions are causing California's climate change strategy to be written.

January 30, 2008
Letter to Chuck Schulock of CARB urging that fair and equitable funding and fees be adopted

December 10, 2007
Comments on AB 32 Scoping Plan

December 5, 2007
Comments on the CARB’s Draft Mandatory Reporting Regulation

July 24, 2007
Comments on Market Advisory Committee Report
When developing a cap-and-trade system to reduce greenhouse gas, we recommend that CARB recognize the costs savings a cap-and-trade system has over a command-and-control rule.

July 24, 2007
Letter to California Air Resources Board (CARB)
Request that all information submitted to CARB regarding AB 32 implementation be made public.

June 29, 2007
Letter to Gov. Schwarzenegger and other state leaders regarding CEQA Lawsuits
Over 40 organizations joined AB 32 IG in asking state leaders to remedy the problem of project-delaying lawsuits that claim CEQA requires an analysis of climate change impacts.

June 7, 2007
Letter to CARB regarding greenhouse gas fees
Fees charged for greenhouse gas programs managed by the state should be appropriately balanced between emitters and capped at a level adequate to cover the mandated regulatory program of AB 32, said the AB 32 Implementation Group in a letter to the California Air Resources Board.

May 8, 2007
Comments to CARB on Discrete Early Actions draft
In written comments to CARB regarding proposed Discrete Early Actions to reduce emissions, the AB 32 Implementation Group focused on whether the draft actions are cost-effective. The submitted letter states, “Staff did not provide any guidance on their definition of cost-effectiveness nor was any information provided on the methodology or legal basis for such a definition. We hope that such information will be forthcoming …”

April 24, 2007
Recommendations to MAC on market mechanism to accompany California's greenhouse gas program
In addition to suggesting specific principles and guidelines for the MAC to follow, we argued that a well-designed market mechanism – one with high transparency, depth of trade and low transaction costs – will speed new technologies to the market and minimize the cost of compliance to achieve the greenhouse gas (GHG) emission reductions envisioned by AB 32.