WHAT WE'RE SAYING
When You Are Stuck In A Hole, The First Thing to Do is Stop Digging
August 11, 2011
AB 32 Implementation Group's Comments regarding CARB’s 1st cap-and-rrade 15-day rulemaking package
December 9, 2010
AB 32 Implementation Group's comments to CARB regarding the proposed cap-and-trade regulation
July 9, 2010
AB 32 Implementation Group's comments to CARB regarding the May 23rd Cap-and-Trade/Offset Protocol (Transitioning to Compliance Protocols) Public Workshop.
June 7, 2010
AB 32 Implementation Group's comments to CARB regarding the May 17th workshop on the concepts for a cap-and-trade program
March 12, 2010
AB 32 IG letter the CARB Chair, Mary Nichols regarding the AB 32 Scoping Plan Economic Analysis. Requesting additional time for adequate review of the new economic analysis prior to presentation to the CARB Board and raising key questions that the IG hopes will be answered in the revised economic analysis.
February 4, 2010
AB 32 Implementation Group's letter to the California Air Resources Board Members explaining the AB 32 IG's mission and goals and offering an invitation for the Board Members to attend an AB 32 IG meeting.
January 11, 2010
AB 32 Implementation Group's letter to CARB regarding its cap-and-trade preliminary draft regulation
January 7, 2010
AB 32 Implementation Group's letter to the Economic Allocation and Advisory Committee regarding its "Allocating Emission Allowances Under California' Cap-and-Trade Program, January 2, 2010 Draft"
December 10, 2009
AB 32 Implementation Group's letter to CARB regarding its December 1, 2009 Economic Analysis Workshop, stating that many of the peer reviewers for the economic analysis had good ideas for improving the analysis this year. AB 32 IG encourages CARB to consider their recommendations and use the new analysis to update the Scoping Plan for AB 32.
December 9, 2009
The AB 32 Implementation Group's Letter to the Economic and Allocation Advisory Committee regarding its “Allocating Emission Allowances Under California’s Cap and Trade Program -- November 16 Draft"
November 24, 2009
Statement by AB 32 Implementation Group regarding CARB's preliminary draft proposal for AB 32's cap-and-trade program
October 30, 2009
AB 32 IG Letter to the Economic and Allocation Advisory Committee urging EAAC to recommend four solutions to CARB -- that environmental justice concerns be addressed separate and apart from the design of the cap-and-trade program, that a broad use of offsets and the minimal use of auctioning would minimize the costs of greenhouse gas reduction, that the cap-and-trade program design link seamlessly with national and international programs, and that a sound economic analysis be completed as soon as possible under the guidance of the Legislative Analyst.
October 2, 2009
AB 32 Implementation Group's letter to CARB's Economic and Allocation Advisory Committee discussing the importance of separating environmental justice issues and a cap-and-trade/offset program.
September 16, 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
August 6, 2009
AB 32 Implementation Group's Letter to CARB's Economic and Allocation Advisory Committe offering its perspective on a few components under the Committee's consideration as they relate to the Committee's mission.
April 24, 2009
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
April 17, 2009
Letter to CARB urging the economic analysis be completed by June 30, 2009
"The economic analysis should be the cornerstone of the policymaking process rather than an addendum to the regulation process."
April 17, 2009
Letter to Governor Schwarzenegger regarding enhanced vapor recovery regulation and Low Carbon Fuel Standards
March 4, 2009
Letter to CARB regarding Low Carbon Fuel Standards (LCFS)
AB 32 IG expresses concerns about CARB's failure to complete and release all of the life cycle analyses and economic analysis of the LCFS prior to finalizing and releasing it regulation packed for the LCFS.
February 25, 2009
Discussion of a Carbon Tax for California
We urge the Commission to abandon the discussion of a carbon tax as a solution to the state budget problems.
February 13, 2009
AB 32 IG's comments to CARB on the Agency’s conceptual proposal for adopting an administrative fee regulation for implementing AB 32 (Global Warming Solutions Act).
February 4, 2009
Comments to the Western Climate Initiative Regarding the January 6, 2009 - WCI Background Document and Progress Report Essential Requirements of Mandatory Reporting for the Western Climate Initiative, Third Draft
To read the WCI's Background Document, click here.
January 22, 2009
Letter to CARB Regarding Low Carbon Fuel Standards
The Low Carbon Fuel Standard (LCFS) is the first major regulation in the series of rules necessary to implement the AB 32 Scoping Plan. The process surrounding evaluation and adoption of the LCFS will set the tone and standard for future rulemaking, so it's important that this process meets the assurances offered by CARB during Scoping Plan development."
January 16, 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 (Oct. 24, 2008)
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