Submitted Comment Name Anthony Myint Affiliation Zero Foodprint Subject Social Cost of Carbon and Money for Ton vs. Ton for Ton Message There is broad disagreement about the social cost of carbon ranging from $5/ton (Trump) to $51/ton (Obama era) to $190/ton (Biden/EPA) to $1056/ton (Nation Bureau of Economic research) if you include lost revenue and a new study by Columbia University estimates the cost as $3567/ton if you include mortality valuation. I'm glad to share all the links and research papers. The voluntary carbon market includes carbon credits for as low as $3 per ton, typically for overseas projects and not enough to spur crucial decarbonization. It is a race to the bottom/cheapest offset and it can be gamed, AND often the majority of the funds are used for intermediaries (finance. registration, etc.), so it is inefficient. The implementation questions in your process address crucial, but completely unnecessary issues and particulars around the technicalities and complexities of carbon accounting. Let me explain. There is a shift in thinking from Ton for Ton approaches to a Money for Ton approach that would accelerate local/regional/supply chain/insetting projects, while circumventing the need for complex MRV. This is a shift even from within the carbon credit industry that would mean credits are eligible activites, but that what truly matters is how much money--beyond business as usual (~$0) each company uses for implementation of decarbonization efforts. https://carbonmarketwatch.org/publications/joint-letter-common-ground-c… As you implement your crucial policies, I suggest you allow companies to either comply through either a) a very simple contribution model or b) the complex carbon disclosure and action model. For example, they could either use 1% of revenue, or 0.5% or something and the funds could go to CARB and into the GGRF, or they could engage in b). As you implement this, it is crucial that the contribution be calculated based on a % of revenue (not profit--can be gamed). This would ensure compliance because every company can participate from day 1. Basically they pay an extra $X00,000,000 to the state in fees, collected by the treasurer like an optional tax, or the company con do their due diligence and can reduce their net outlay by engaging in very complex MRV. This would also position the state to lower the threshold to companies with $500M in revenue and then $100M in revenue, then $50M, then $10M, $1M etc. This is basically just the economy internalizing the externalities and doesn't require carbon accounting. But then the "good actors" could get an exemption and just pay based on their carbon footprint. File Upload (i.e., Attachments): N/A
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