Near Zero comment letter to the California Air Resources Board re: oversupply, banking rules, and offsets issues in the preliminary discussion draft cap-and-trade regulations (Mar. 16, 2018) (with Mason Inman and Michael Mastrandrea) (PDF).
In order to achieve a 2/3 vote to extend cap-and-trade, several changes to the current market design will be necessary. SB 775 is the first serious attempt to address the challenge of extending carbon pricing after 2020 and continues to be the only proposal that offers a solution to the real-world constraints facing legislators today.
Now that Trump's executive order on climate is here, it is clear that the United States will most likely miss its Paris target—but there has never been a credible case that the United States was on track in the first place.
Bulletin of the Atomic Scientists (Jan. 10, 2017) (with Michael Wara)
In order to bring its new climate target within practical reach, California must renew its commitment to carbon pricing. But first, climate policy advocates need to build a broad coalition that benefits from the state’s plans for deep de-carbonization.
Comment letter to the California Air Resources Board re: transparency, policy specificity, and energy forecasting uncertainty in the draft 2030 scoping plan process (Nov. 21, 2016) (with Michael Wara) (PDF).
Comment letter to the California Air Resources Board re: market design, target-setting, and other substantive policy issues in its proposed post-2020 cap-and-trade program (Sept. 19, 2016) (with Michael Wara) (PDF).
Comment letter to the California Air Resources Board re: legal authority to extend cap-and-trade after 2020 and use cap-and-trade for federal Clean Power Plan compliance (Sept. 19, 2016) (with Michael Wara) (PDF).
Comment letter to the California Air Resources Board re: use of 20-year AR5 GWPs in the Draft Aliso Canyon Methane Leak Climate Mitigation Program (Mar. 24, 2016) (with Michael D. Mastrandrea, Emily Grubert, and Aaron Strong) (PDF).
Brief of amici curiae climate scientists Ken Caldeira, PhD, et al. in support of defendants-appellants in Rocky Mountain Farmers Union v. Corey, 730 F.3d 1070 (9th Cir. 2013) (with Deborah Sivas, Alicia Thesing, Leah Russin, and Matthew Armsby of the Stanford Environmental Law Clinic) (PDF).